Clinton Power Station Unit 1, Submittal of Reports Associated

Adenow 300 Winfield Road arrenvdle. IL 60555 Exolon Generation 30 657 2000 Office 1 Washington, A U. RS-12-204 November Subject: References This Exel()n Limitations information GE14i Reference poolside measurement included TIN: Attachments Attachments S. under under letter Nuclear Document ITA Clinton Facility NRC gamma in 10 29,2012 Attachments I and 3 contain proprietarycompletes information. Withhold from public disclosure 10 bundle, 2 : section, attachments is DC Docket CFR

under 10 CFR 2.390.reported When separated from Attachments 1 and 3, this cover letter is Regulatory CFR required system Operating Power 1 Nuclear Reports 1. 2. 1

decontrolled. 20555 and scan Control Generation 2.390. Letter Company, and Re: Letter "Reports Isotope Global May 2 performed in No. .

390 RS-12-204 the 3 Station, the Request Reference (COINS) measurements 3 by 14, contain Associated Fuel 50-461 from from 1 contain . Commission License reporting Desk When Nuclear results the

November 29, 2012 Test through When 2012 Associated (GNF) LLC), C D. NRC as Unit by Assemblies to . examination separated proprietary S M GNF of separated proprietary 1 No. Fuel U. S. Nuclear Regulatory Commission Modify Facility . 1 · 4 . requirements "Clinton Goodwin with the Gullott GE14i

ATTN: Documentof Control Desk NPF discussed and for (GNF) this Washington, DC 20555 with poolside decontrolled. Results decontrolled Clinton - segmented Isotope (Exelon 62 letter from (TAC Power Results requirements. from information. (U GE14i information Clinton Power Station, Unit 1 . . S. of visual associated with Operating in Attachments NO Facility Operating License Power No. NPF-62 Attachments Station, Test Post-Irradiation NRC) Generation Condition

NRC Docket No. 50-461 of Isotope . ME1643)," Post-Irradiation rod and . Assembly Station. to hot . Withhold Unit License poolside The

Subject: C.

Withhold Reports Associated with Results of Post-Irradiation Examination (PIE) of Global Test 11, cell G.

Nuclear Fuel (GNF) GE14i Isotope TestCompany, Assembly (ITA) 1 No.1 remaining the 1 dated of and The Assembly Pardee destructive (ITA) and Examination in Warrenvllle,lL 4300 630 the combined PIE -Issuance from reporting 3, Support

from References: 1. Letter Examination

from C. S. Goodwin (U - S. NRC) 657 3, to C. G. January Pardee (Exelon Generation Conditions Winfield this Company, LLC), "Clintonresults, this Power Station, Unit No.1 -Issuance of Amendment 2000 (Exelon LLC) results, Re: Request to Modify Facility Operating License in Support of the Use of public (ITA)," public cover 60555 Road examination, Office

cover Isotope Test Assemblies of instrumentation (TAC NO • ME1643)," dated January 15, 2010 of of to (PIE) 15, of the this Amendment u. Generation disclosure of and a dated disclosure 2. Letter from D. M. Gullott (Exelon(PIE) Generation Company, letter 2010 LLC) to U. S S. NRC, S Use the letter GNF

"Reports Associated with Results of Post of

. -Irradiation Examination (PIE) of NRC,

Global Nuclear Fuel (GNF) GE14i Isotope Test AssemblyGlobal (ITA)," dated of of is is are May 14, 2012

This letter completes the reporting requirements associated with the PIE results, of a GNF GE14i ITA bundle, performed by GNF for Clinton Power Station. The reporting of this information is required by the NRC as discussed in Condition 11, of the Conditions and Limitations section, in Reference 1

Reference 2 reported the results of the poolside visual and poolside combined instrumentation measurement system (COINS) examination requirements. The remaining results, of the poolside gamma scan measurements and segmented rod hot cell destructive examination, are included in attachments 1 through 4 of this letter.

Attachments I and 3 contain proprietary information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 1 and 3, this cover letter is decontrolled. November 29, 2012 U. S. Nuclear Regulatory Commission This U. November Page affidavits There and Portions NRC respectfully are concerning Attachments 10 10 Patrick Manager Page 2 Re Attachments Attachments S. m CFR CFR under under 4 6. 3 2. 5. provided 1 6, submittal . . . Nuclear and Attachments I and 3 contain proprietary information. Withhold from public disclosure 2 • • • • • • are set Affidavit Affidavit Clinton Clinton Hot Hot R. 2.390. under 10 CFR 2.390. When separated from Attachments 2.390, I and 3, this cover letter is of signed - to Attachment Attachment to Attachment Attachment examination examination Attachment gamma Attachment of of Pin-by-Pin addresses, 10 no Simpson forth 10 29,2012

decontrolled. the licensing Cell Cell this requested the the NEDC-33784P. NEDC-33787P : in CFR regulatory CFR Regulatory is R. information GE14i GE "Public Attachments the 1 letter, Non-proprietary proprietary proprietary for for 1 Inspection This submittal isInspection subdivided as follows. subdivided by and scan and 2.390. 14i 2.390. basis NEDC-33787P NEDC-33784P GNF, gamma with 2 4 3 1 5 • Attachment 1 provides a proprietary version, including an affidavit from GNF6 attesting Pin-by-Pin Pin-by-Pin please 3 contain of of 3 that inspections, measurements. provides provides provides provides provides provides

to the proprietary nature of the information,commitments of the results of a hot cell destructive contain GE14i GE14i on Commission the When specificity, When

examination of GE14i rod in of of segments. the nature nature as which 2 scan Attachments contact Clinton owner • AttachmentClinton 2 provides a non-proprietary version of the results of a hot cell destructive and information follows.

examination of GE14i rod segments. rod rod versions a separated the the a a a proprietary Gamma Gamma separated proprietary measurements. of of proprietary

• proprietary non-proprietary Attachment 3 provides a proprietary version, including an affidavit from GNF attestingnon-proprietary the Revision Revision 4, exemptions, segments. segments. of affidavit affidavit the the the Cycle Cycle to the proprietary nature of the information,Mr. of the results for the GE14i Pin-by-Pin respectively. contained information gamma scan measurements. the information, decontrolled. information, considerations decontrolled. Thomas of Scan • Scan Attachment 4 provides a non-proprietary version of the results for the GE14i 1 information. be 13 13 the from 0 0 and from from Pin-by-Pin gamma scan measurements. from information. information withheld version, version, GE14i GE Report Report • Attachment 5 provides the affidavit from GNF attestinginformation to the proprietary nature requests in 3 Attachments J. 14i Attachments GNF of NEDC-33787P GNF may version are version this

• Attachment 6 provides the affidavit fromGriffith GNF attesting to the proprietary nature of of Rod Rod proprietary from including including - - letter be

of NEDC-33784P. attesting attesting the The the listed Non-Proprietary Proprietary for Segments Segments . withheld of of contained results results at Withhold public Withhold affidavits, .

Portions of the information in Attachments 1 and 3 are proprietarywithholding." to GNF, and are supported by the the Should in affidavits signed by GNF, the owner of the information.(630) The affidavits, provided in Attachment 5 1 an an 1 paragraph to to results and 6, set forth the basis on which the information may be withheld from public disclosure by theresults to and and disclosure of for the the affidavit from affidavit

NRC and addresses, with specificity, the considerations657-2818. listed in paragraph (b)(4) of GNF, - - a you in the from from provided 3, 3, Non-Proprietary Proprietary proprietary 10 CFR 2.390, "Public inspections, exemptions, requests for withholding." Accordingly,proprietary it is hot for Attachments of public this this respectfully requested that the information be withheld from public disclosure in accordance with GE14i have and a Accordingly, cell the (b)(4) public from from public 10 CFR 2.390. Non-proprietary versions of the information contained in Attachments 1 and 3 hot in cover cover

are provided in Attachments 2 and 4, respectively. are destructive disclosure GE14i accordance any in cell Pin-by-Pin GNF GNF of Attachment nature nature supported disclosure disclosure

There are no regulatory commitments contained in thisquestions letter. Should you have any questions destructive letter letter 1 attesting concerning this letter, please contact Mr. Thomas J. Griffith at (630) 657-2818. attesting and it is by is is 3 with the by

e iectf^ullly, 5

Patrick R. Simpson Manager - Licensing

Attachments:

1- Hot Cell Inspection of Clinton Cycle 13 GE14i Rod Segments - Proprietary 2. Hot Cell Inspection of Clinton Cycle 13 GE14i Rod Segments - Non-Proprietary 3. Clinton GE14i Pin-by-Pin Gamma Scan Report - Proprietary 4. Clinton GE14i Pin-by-Pin Gamma Scan Report - Non-Proprietary 5. Affidavit for NEDC-33787P Revision 0 6. Affidavit for NEDC-33784P Revision 0

Attachments 1 and 3 contain proprietary information. Withhold from public disclosure under 10 CFR 2.390. When separated from Attachments 1 and 3, this cover letter is decontrolled. Hot Cell Inspection of ATTACHMENT Clinton Non·Proprietary Cycle 13 2 GE14i ATTACHMENT 2 Rod

Hot Cell Inspection of Clinton Cycle 13 GE14i Rod SegmentsSegments

Non-Proprietary

GN- Global GNr' A

Global Nuclear Fuel Joint Global Nuclear Fuel Hot Venture

A Joint Venture of GE. Toshiba, & Hitachi Nuclear of GE. Cell

NEDO-33787 Toshiba NON-PROPRIETARY Revision 0 . & DRF Section 0000-0153-4519 R1 Fuel Hitachi Copyright

Inspection 2012

GE14i November

NON-PROPRIETARY2012 INFORMATION- CLASS I (PUBLIC) Global All INFORMATION Rod Rights Nuclear Reserved of Segments

Hot CellFuel Inspection of Clinton Cycle 13 Clinton - Global - Americas, GE14i Rod Segments CLASS DRF I (PUBLIC) Section LLC Nuclear Cycle 0000-0153-4519 November NEDO-33787 13 Revision Fue.l 2012 R1 0

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) unauthorized The the purpose proprietary completeness, This indicated purpose(s) design, is IMPORTANT

INFORMATION NOTICE a other by non-proprietary engineering, This is a non-proprietary version of the document NEDC-33787P, Revision 0, which has the infonnation an use, accuracy, than

proprietary information removed. stated Portions of the document that have been removed are open

indicated by an open and closed bracket as shown here [[ ]]. GNF that and in NOTICE makes or Non-Proprietary the and closed removed. for version

IMPORTANT NOTICE REGARDING THE CONTENTS OF THIS REPORTusefulness transmittal oth~r which no

PLEASE READ CAREFULLY PLEASE bracket REGARDING INFORMATION representation of infonnation

The design, engineering, and other information contained in this document is furnished solely for NEDO-33787 it Portions the the purpose(s) stated in the transmittal letter. The use of this information by anyone of for any is as letter. the READ Information - document purpose other than that for which it is intended is not authorized; and with respect to anyintended shown

unauthorized use, GNF makes no representation or warranty, and assumes no liability asinfonnation to the of contained 11

completeness, accuracy, or usefulness of the information contained in this document. The THE or CAREFULLY here Revision the is warranty, NEDC-33787P, NOTICE use not CONTENTS [[ document Class contained of in authorized; 0 this this I and (Public) document infonnation that assumes in ]]. OF Revision this have and THIS document. is no with furnished been by 0, liability REPORT anyone respect which removed solely as for has to to any any are the the for

NEDO-33787 Revision 0 Acronyms 2. Abstract 3. 4. Non-Proprietary Information - Class I (Public) 1. Mechanical GE14i Introduction Summary 3.1 3.4 3.3 3.5 3.6 3.7 3.2 Visual Visual Visual Visual Visual Visual Inspection Optical ......

TABLE OF CONTENTS Segmented and and Inspection ...... Abbreviations Inspection Inspection Inspection Inspection Inspection Microscopy Acronyms and Abbreviations ...... vConclusions

Abstract ...... vi Isotope Non-Proprietary ...... of

...... 1-1of of of of 1. Introduction of of Inner Intact Intact Centering Inner Canister Rod Description ...... 2. GE14i Segmented Isotope Rod Description ...... 2-1 Outer 3. Mechanical Inspection ...... 3-1 TABLE OF Surface Surface Inner As-Received NEDO-33787

As-Received Segments...... Tube 3-1 3.1 Visual Inspection of Intact and 3.2 Visual Inspection of Inner Surface of Outer Tube ...... 3-1Peg Capsule Information Cobalt of of

Peg for Inner Capsule ...... and 3-1 3.3 Visual Inspection of Centering for Inner Outer 3.4 Visual Inspection of Intact Inner Capsule ...... 3-2 ...... Inner Inner iii CONTENTS . Tube ...... 3-2 Segments ...... 3.5 Visual Inspection of Inner Surface of Inner Capsule Targets ...... Revision

...... Capsule 3-3 3.6 Visual Inspection of Canister and Cobalt Targets Tube . Capsule Tube ...... 3.7 Optical Microscopy of Outer Tube and Inner Tube Samples ...... 3-3 - Class ......

...... 4-1 ...... 4. Summary and Conclusions Samples 0 Tube ...... I (public) ...... ' .. 4-1 3-2 3-1 3-1 2-1 3-2 3-1 3-1 3-3 3-3 1-1 vi v

III

NEDO-33787 Revision 0 Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Figure Non-Proprietary Information - Class I (Public) LIST OF FIGURES 4 6 2 5 9 3 7 8 10 23 22 20 21 1 25 24 14 15 12 11 16 13 19 18 17 Figure 1 Visual Inspection of As-Received Segment 9 (S/N 0166CBT) ...... 3-5

Figure 2 Visual Visual Visual Visual Visual Visual Visual Visual Visual Visual Visual Visual Visual Visual Visual 9 Magnifications; Visual Visual Extraction Polished and Etched Polished Stuck Calibration [[ Polished Etched Showing Showing [[ Visual InspectionShowing of As-Received Segment 9 (S/N 0166CBT) ...... 3-6 Figure 3 Visual Inspection of As-Received Segment 9 (S/N 0166CBT) ...... 3-7 9 ...... Figure 4 Target Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection Inspection

Visual Inspection of As-Received Segment 6 (S/N Inspection 0327CBT) ...... 3-8 Metallographic Metallo Metallographic Metallographic Cross-Sections Metallographic [[ [[ Figure 5 Visual Inspection of As-Received[[ Segment 6 (S/N 0327CBT) ...... 3-9 of Non-Proprietary Scale in Figure 6 Visual Inspection of As-Received Segment 6 (S/N 0327CBT)Targets ...... 3-10 grap Canister Figure 7 Visual Inspection of As-Received SegmentSmallest 3 (S/N 0315CBT) ...... 3-11 at of of of of of of of of of of of of of of of of of ' hic Original As-Received As-Received As-Received As-Received As-Received As-Received As-Received As-Received As-Received As-Received Inner Capsule

Figure 8 Inner Inner Inner Extracted Visual Inspection of As-Received Segment 2 (S/N Canisters 0436CBT) ...... 3-12 Utilizing NEDO-33787 LIST Cross-Section Figure 9 Visual InspectionCross-Section of As-Received Segment 2 (S/N 0436CBT) ...... 3-13 from Cross-Sections Cross-Sections Division Surfaces Capsules Capsules Figure 10 Visual Inspection of As-Received Segment 2 (S/N 0436CBT) ...... Surfaces 3-14 Information Magnifications Centering OF Segment from Targets

Figure 11 Visual Inspection of Inner Surfaces of Outer Tubes from SegmentsCanister 2, 6, and ]] ]] . Segment Segment Segment Segment Segment Segment Segment 9 ...... 3-15 Segment Segment Segment IV FIGURES ]] ]] is ...... of of Segments from from . .... Revision 20 Figure 12 . Visual Inspection...... of Capsule Centering Pegs from Segments 2, 6, and 9 ...... 3-16 from from Outer Inner from ...... 0166CBT Pegs Extraction Microns from from from Figure 13 Visual Inspection of Inner Capsules from Segments 2, 6, and 9 ...... 3-17 - Segments Segments ...... Class Segment 6 2 Segment 6 6 9 3 9 2 2 9 Capsules

Figure 14 Segments Tubes

Visual Inspection of Inner Capsules from Segmentsof 2, 6, and 9 ...... 3-18 from (SIN (SIN (SIN (SIN (SIN (SIN (SIN (SIN (SIN (SIN Segment Segment Segment 0 2,

Figure 15 Visual Inspection of Inner Surfaces of Inner100, Capsules from Segments 2, 6, I ...... 6, ... .. (Public) Segments 0436CBT) 0315CBT) 0327CBT) 0327CBT) 0 0436CBT) 0436CBT) 0327CBT) 0 0166CBT)

and 9 ...... Tool 3-19 ...... and from 2, 2, 166CBT) 166CBT) . 250, ...... 6 9 Inner ...... from 6,

Figure 16 6, Extraction of Targets Utilizing Outer Canister Extraction Tool ...... 3-20 2,6, . . 9 6 9 9 ...... and 9 and Segments .. Outer Inner Inner and Figure 17 ......

Visual Inspection...... of Extracted Targets from Segments 2, 6, and 9 ...... 3-21 ...... Segments and . Tube ...... Tube 2, Figure 18 9

Visual Inspection of Canisters from Segments500X 2, 6, and 9 ...... 3-22 ...... Tube Tube ...... 6, Tube Figure 19 Stuck Target in Canister from Segment 0166CBT ...... 9 3-23 ..... and Showing Showing . 2, ...... Figure 20 Calibration. Scale at Original Magnifications of 100, 250, and 500X ...... ]] ...... 6, 2, 9 ......

Magnifications; Smallest Division is 20 Microns ...... 3-24 ...... and 6, ...... Figure 21 ...... Polished Metallographic Cross-Sections from Segment...... 6 Outer Tube ...... Showing [[ .. ]] ...... 3-25 3-12 3-11 3-10 3-16 3-17 3-13 3-14 3-24 3-18 3-15 3-19 3-27 3-25 3-20 3-28 3-26 3-22 3-23 3-21 3 3-6 3-9 3-5 3-7 3-8 -

Figure 22 Etched Metallographic29 Cross-Section from Segment 6 Outer Tube Showing [[ ]] ...... 3-26 Figure 23 Polished Metallographic Cross-Sections from Segment 9 Inner Tube Showing [[ ]] ...... •...... 3-27 Figure 24 Polished Metallographic Cross-Sections from Segment 9 Inner Tube Showing [[ ]] ...... • ...... •...... •3-28 Figure 25 Etched Metallographic Cross-Section from Segment 9 Inner Tube Showing IT ]] ...... 3 29

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) ID GWdlMT BWR Term OD GNF GEH ITA VNC ACRONYMS AND ABBREVIATIONS SIN

Term Definition

BWR Boiling Water Reactor Definiti GigaWatt-Day/Metric Inside Boiling GE Outside Global Isotope Vallecitos GEH GE Hitachi Nuclear Energy Serial

GNF Global Nuclear Fuel Hitachi Non-Proprietary Number Diameter Nuclear ACRONYMS Test on Water Diameter

GWd/MT GigaWatt - Day/ Metric Ton Nuclear Nuclear Assembly Reactor

ID Inside Diameter Fuel NEDO-33787 Center

ITA Isotope Test Assembly Energy

OD Outside Diameter Ton Information S/N Serial Number AND

v VNC Vallecitos Nuclear Center Revision ABBREVIATIONS - Class 0 I (Public)

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) Nine mechanical rod exhibited GEH Clinton [ ]] [[ was rod Vallecitos Power segments

ABSTRACT excellent irradiated

Nine rod segments from GE14i bundle JYK690 in the [[ ]] pin position were retrieved from integrity. GWdJMT Station

Clinton Power Station for non-destructive and destructive post-irradiation examination at the Nuclear mechanical GEH Vallecitos Nuclear Center hot cells in Sunol, California. The [[ ]] segmented isotope from rod was irradiated for one full cycle during Cycle 13 in an assembly that achieved a for for The Non-Proprietary GE14i burnup. Center [[ ]] GWd/MT burnup. The examination focused on characterizing the rod segments' one mechanical integrity. The examination confirmed that the GE 14i segmented isotope rod non-destructive examination full integrity bundle

exhibited excellent mechanical integrity and performed as intended. hot The NEDO-33787 cycle cells examination JYK690 and ABSTRACT Information in during confirmed performed and Sunol, vi in destructive Revision Cycle the California. focused - [[ that as Class 13 intended. 0 the on post-irradiation in ]] I (Public) The characterizing pin GE an position 14i [[ assembly segmented ]] were examination segmented the that retrieved rod isotope achieved segments' isotope at from rod the a

NEDO-33787 Revision 0 process The maintained visual the provides examination. (GEH) The microscopy Cycle opened, irradiated isotope Non-Proprietary Information - Class I (Public) Segmented [ ]] [[ following objectives 13. inspection rod Vallecitos of removal 1. INTRODUCTION a summary in A retrieving isotope design and of single position The Segmented isotope rods containing nickel-coated, reactor grade Co-59 isotope targets have been a selected sections of GE14i irradiated in a GE14i Isotope Test Assembly (ITA) for one 23-month cycle in Clinton's has of JYK690 of by the rods Nuclear segmented

Cycle 13. A single segmented isotope rod (Serial Number (S/N) 0196CBT) was retrieved fromof not all and verifying cobalt in examination the components.

the [[ ]] position in the assembly JYK690 and delivered to the GE Hitachi Nuclearof Energy intact Isotope containing Non-Proprietary degraded the removing the

(GEH) Vallecitos Nuclear Center (VNC) located in Sunol, California for post-irradiationhot cell bundle Center assembly examination. The JYK690 bundle achieved an exposure of [[ ]] GWd/MT.targets report rod isotope that

The objectives of the examination were to confirm successful performance of the segmented Test achieved 1. work segments, during NEDO-33787 nickel-coated, the were cobalt summarize (VNC) isotope rod design by verifying that the physical integrity of the segmented isotopefrom rods has been INTRODUCTION Assembly JYK690 rod physical

maintained and has not degraded during irradiation and to demonstrate the functionality performed and Information to irradiation targets the

process of retrieving and removing cobalt targets from the segmented isotope rods. This report (Serial an confirm located provides a summary of the hot cell work performed to complete these objectives. visual 1-1 exposure three and details integrity (ITA) Revision reactor from The following sections of the report summarize details of the hot cell examination that included Number to delivered inspection successful segments in complete

visual inspection of all intact rod segments, visual inspection of the three segments that were - and of Class the of

opened, removal of cobalt targets from the three segments that were opened, and optical for Sunol, of grade the to [[ 0 (SIN) segmented microscopy of selected components. the one demonstrate I to hot (Public) these segmented of Co-59 that the performance California 0196CBT) cell examination cell 23-month the GE ]] objectives. were three isotope GW isotope Hitachi the isotope dlMT. opened, segments for cycle was of targets functionality rods. Nuclear post-irradiation the retrieved rods that in and This segmented have that Clinton's has included Energy optical report were from been been and

NEDO-33787 Revision 0 mating nominal The bundle. identification Each rod segment the Non-Proprietary Information - Class I (Public) And inner segmented there shoulder. pre-irradiation tube, by segment is 2. a

2. GE14I SEGMENTED ISOTOPE ROD DESCRIPTION [[ ]]. numbers, Zircaloy-2 it GE14I isotope is The segmented isotope rod is comprised of [[ ]].There The consists then nominal pre-irradiation length of [[ ]] inches and the length of [[ The ]] length is ]] inches, excluding the portion of the male threaded connector beyond the with rod called threaded SEGMENTED Non-Proprietary inches, canister an

mating shoulder. The threaded male connector beyond the mating shoulder lengthens each of ]] is #1 inner segment by [[ ]] inches. After arrival at VNC, the rod segments were assigned an inches. of an comprised being outer identification numbers, with #1 being at the bottom of the bundle and #9 being at the top of the excluding [[ "inner within male Zircaloy-2 bundle. NEDO-33787 Zircaloy-2 at After connector

Each rod segment consists of an outer Zircaloy-2 barrier tube ("outer tube") thatcapsule." has [[ the each of Infonnation the ISOTOPE [[ bottom arrival inner barrier ]]. There is an inner Zircaloy-2 barrier tube within each outer tube ("inner tube"). portion 2 - 1

And there is a Zircaloy-2 canister within each inner tube ("canister"). The canister has [[ barrier Revision beyond tube of at tube - of the VNC,

]]. When the canister is sealed within Class tube ("canister"). the ROD

the inner tube, it is then called within bundle an "inner capsule." ]]. the 0 male ]] ("outer I When the inches (Public) mating DESCRIPTION each threaded and rod tube") the and The #9 outer segments shoulder canister the being canister connector that tube length has at is lengthens were ("inner the has sealed [[ of beyond top [[ [[ assigned ]]. tube"). within of each The the the

NEDO-33787 Revision 0 bottom 3.1 The rod opened, are as-received or This general anomalies. Kollmorgen 3.3 ]]. connectors. a Figures Four 3.2 for approximately Sectioning inner Non-Proprietary Information - Class I (Public) I inch portion lower in Segment segments, VISUAL VISUAL VISUAL GE14i section contains section inch good surface major end, condition and 1

3. MECHANICAL INSPECTION endplug through of long of condition segmented condition. A and optical [[ 2. periscope divisions the the INSPECT INSPECTION This section contains the results of visual inspection ofINSPECTION the outer portion of the nine as-received common visual the blanks of Photographic rod segments, visual inspection of the inner components of the three rod segments thatthe were centering male extensions. of middle 10 the microscopy opened, and optical microscopy of sections of the outer tube and inner tube from Segmentcladding 6. the and the ]]. inspection show of isotope threaded and from Each outer VISUAL INSPECTION OF INTACT AS-RECEIVED SEGMENTS set Non-Proprietary 3.1 I threaded the results exhibit ON of 3. 0.1 of peg the

The GE14i segmented isotope rod was received inouter the disassembled condition without its upper outer the documentation segment top OF OF OF ]]. MECHANICAL Each digital tube rod inch segments or lower endplug extensions. Each of the nine separate segments was visually inspected in the of connector that of segment of [[ The INTACT CENTERING to INNER connectors sections tube was as-received condition. Each segment was placedtube in a slotted tray adjacent to a ruler that had visual NEDO-33787 the of could minor bottom is photographs

1 inch majorcondition divisions and 0.1 inch minor divisions. The segment was then viewed through a was the received in from inner Kollmorgen periscopeintegral from top to bottom in 90 degree increments to identify any visible Information in for inspection general. SURFACE for nine of divisions. placed be

A common set of digital photographs were taken of each segment to document the AS-RECEIVED anomalies. the of Segments Segments in the and components Segments 3 the

general condition of the threaded connectors examined and welds on each end, the serial number on the - separate of as-received 1 in to 90 outer PEG Revision welds

bottom end, and the cladding outer tube in general. were the in inner I the the NSPECTION degree of a - centering The disassembled Figures 1 through 10 show the segments in the as-receivedOF condition. In general, all segments tube FOR 2, the outer slotted Class 6 taken 2, segments surface on . and

are in good condition and exhibit [[ 6, OUTER of 6, 0 segment outer and condition. increments each and The INNER and I SEGMENTS tube's the 9 of (Public) tray inner and pegs is 9 each portion end, 9 three blanks was shown were passed adjacent TUBE near was condition male is CAPSULE tube segment the visually shown In rod to clam-shelled of then the in from were general, serial and through identify the segments Figure to top viewed in without to female nine inspected Segment a number obtained of Figure ruler document all and 3.2 VISUAL INSPECTION OF INNER11. SURFACE OF OUTER TUBE the n visible any as-received so through that segments its threaded that segment released Four inch long blanks of the outer tube [[ from Segments 2, 6, and 9 were clam-shelled so that the that 12. 6. on in The blanks were obtained from upper were inner surface of the outer tube could be from examined. had [[ the the the approximately the middle of the segment for Segmentsthe 6 and 9 and near the top of the segment a for Segment 2. Photographic documentation of the inner surface is shown in Figure 11. [[

]]• 3.3 VISUAL INSPECTION OF CENTERING PEG FOR INNER CAPSULE Sectioning of the male threaded connector for Segments 2, 6, and 9 passed through and released a portion of the centering peg that is integral to the outer tube's male and female threaded connectors. [[ ]]. The condition of the centering pegs is shown in Figure 12. [[

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) removing placed The 3.4 cut the top were 90 established of divisions. Figures 3.5 Four remove that documentation segment surface from in Section the degree surface end and VISUAL VISUAL the inner inch taken intact approximately in of bottom caps it 13 inner was from a the long the 3.7. increments The and capsules deburred, of by slotted inner and examined male inner INSPECTION INSPECTION surface each placing of blanks the 14 capsule end ]]• welds the capsules show inner threaded tray caps tubing, ]]. 3.4 VISUAL INSPECTION OF INTACT INNER CAPSULE capsule from the inner to of the of a was on the metallographically adjacent Non-Proprietary at

The inner capsulescapsule. from Segments 2, 6, and 9 were released from their rod segments by inner identify the the red each Segments an were middle which surface

removing the male threaded connector of each segment. Once the segment wascondition opened and the in then connector inner inner paint angle OF OF capsules cut surface deburred, the inner capsules easily slid out by tilting the segment. The outer the surfaces end, then viewed to any were of the intactThe inner capsules were then visually inspected. An arbitrary zero degree reference was INTACT INNER zero capsule capsule is NEDO-33787 dot of to a

established by placing a red paint dot near the top of each inner capsule. Each segmentand was shown visually of 2, ruler visible view inner of caused near the degree placed in a slotted tray adjacent to a ruler that had 1 inch major divisions and 0.1 inch minor easily . the 6, through the Information each SURFACE tube

divisions. The capsule was thentube viewed through a Kollmorgen periscope from top to bottom in to that the intact and surface INNER segment in the cladding. anomalies. inspected. slid 90 degreeinvestigate increments to identify any visible anomalies. A common set of digital photographs 3-2 by Figure orientation segment. end from had could ]]. top 9

were taken]]. of each capsule in the zero degree orientation to document the general condition of a Revision twisting inner out were Kollmorgen cap of the end caps and weldsNumerous on each end, and the cladding. Additional photographs were taken of the of CAPSULE A 1 Segments - by 15. for Additional photographs Segment be inch OF

top and bottomsmall end caps at an angle to view the end cap female threads. Class capsules. female each tilting An released Once these A examined. [[ and to all INNER 0

Figures 13 and 14 show the condition of the intact inner capsules. [[ major c01l1Il1on arbitrary inner piece document I pulling three threads. (Public) fresh the features 2, the 9 periscope [[ [[ 6, divisions from of segment capsule. segment. CAPSULE and scratches segments. the The set zero the the and their 9 inner of tightly from blanks were degree general was and digital is Each The rod exist were discussed capsule TUBE top clam-shelled opened held 0.1 were outer reference ]]. Photographic segment segments to photographs condition on taken inch canister bottom from the obtained surfaces and further minor of inner was was this the the by so of in to ]]. 3.5 VISUAL INSPECTION OF INNER SURFACE OF INNER CAPSULE TUBE Four inch long blanks of the inner capsule tube from Segments 2, 6, and 9 were clam-shelled so that the inner surface of the inner capsule tube could be examined. The blanks were obtained from approximately the middle of the segment for all three segments. Photographic documentation of the inner surface is shown in Figure 15. [[

]]. Numerous fresh scratches exist on the inner surface of the inner tubing, which were caused by twisting and pulling the tightly held canister to remove it from the inner capsule. The inner surface of Segment 9 [[ ]]. A small piece of the inner capsule from this segment was examined metallographically to investigate these features and is discussed further in Section 3.7.

3-2

NEDO-33787 Revision 0 3.6 The Photographic Examples were shown 3.7 Approximately Segments boiling shown sides examining After evaluate and optical The reference sample at with size examination Figures the [[ [[ Non-Proprietary Information - Class I (Public) high inner VISUAL OPTICAL the conditions samples canisters

3.6 VISUAL INSPECTION OF CANISTER AND COBALT TARGETS occasional as-fabricated within completing ]]. in in magnification. microscopy. was water 21 ]]. second the tube The canisters containing the cobalt targets were removed from the inner capsules from Figure to 2, Figure of the and Images a the

these An example of the Segment 2 canister being pulled from its capsule is waterside Segments 2, 6,]] and 9. 6, in the documentation . full INSPECTION were reactor . inner both containing [ 22 shown in Figure 16. In this figure, cobalt targets are visible sitting both upright and on their and canister Y2 MICROSCOPY targets (F361) [ (Figure 17. ]]. condition 16. the ring slide show

sides within the canister as designed. inch levels of 9. tube polished mounted, After [[ The basic In (BWR) the [[ but Examples of the condition of batches Once of targets removed from each of the three canisters are that An scales. long from as the Non-Proprietary ]]. 20). was this [[ shown in Figure 17. [[ first calibration polishing, the designed. visual the example of were examination the of and ]]• samples to figure, the OF Feature inner sample reactor batches ground [[ the cobalt evaluate polished stuck

Photographic documentation of theetched removed canisters is shown in Figure 18. As expected, there inspections OF inner CANISTER NEDO-33787 removed tube

were occasional targets that were stuck in each of the three canisters (Figure 19); [[ of the cobalt slide OUTER (F360) were water lengths and of in targets the tube inner conditions. the results sample examination Information each targets scales Segment oihd with polished sectioned targets [[ canisters so ]]. of and was and ]]. 3-3 of shown TUBE AND were the [[ for Segment was the were target removed Revision Digital obtained outer are the

primary ]]. [[ 2 three an COBALT removed - is was from AND in placed in canister outer visible Class removal, surfaces AND INNER TUBE SAMPLES shown 3.7 OPTICAL MICROSCOPY OF OUTER TUBEapproximately images the 9. completed, canisters 0 standard from from their INNER

After completing the basic visual inspections and target removal, twopurpose samples were prepared for tube I The micrographs (Public) sitting in being

optical microscopy. The first sample (F360) was obtained from the outer tube from Segment 6 from ]] TARGETS of the each the were two samples two parent Figure and of

and the second (F361) from the inner tube of Segment 9. The outerouter tube is exposed to the both (Figure report metallographic ]]. outer TUBE the of the pulled the boiling water reactor (BWR) reactor water so the primary purpose of its examination was to both Figures of obtained 180 samples The

its ]]. The primary purpose of tube tubes. evaluate the watersideinner [[ 18. the samples ]] inner tube with upright can degree 19); examination of examining the inner tube was to evaluate the [[ SAMPLES primary from three As is were ]]. 23 tube the

]l. from to be the [[ The exposed expected, were capsules through 25 The were document its arc outer canisters and

Approximately '/2 inch long samples were sectioned from their parent tubes.prepared The outer tube is obtained same techniques. Segment purpose outer capsule consistent examined waterside

sample was a full ring but the inner tube sample wasof an approximately 180 degree arc of a ring. [[ on tube was

The samples were mounted, ground and polisheda with standard metallographic techniques. to image there from their ring. tube ]]. are the the for [[ for by of to is is ]]. After polishing, the inner and outer surfaces of both samples6 were examined at high magnification. Once the polished examination was completed, the samples were [[ ]]. Digital images were obtained to document the examination in both polished and etched conditions. [[

]]. Images of the calibration slide scales were placed in the report with the same image size conditions (Figure 20). Feature lengths shown in the micrographs can be obtained by reference to these slide scales. [[ ]] of the inner tube is consistent with as-fabricated levels [[ ]]. [[ ]] of the outer tube is [[ ]] Figures 21 and 22 show the examination results for the outer tube and Figures 23 through 25 for the inner tube . [ [ ]]. The waterside

3-3

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) surface signs some [[ surface of the outer tube has a [[ [[ of ]]. The outer tube shows non· visible of interaction

signs of interaction with the inner capsule (e.g., wear) and is in excellent condition. There is the some [[ outer

]]. tube has with [[ N the on-Proprietary a inner [[ NEDO-33787 capsule Information (e.g., 3-4 ]]. wear) Revision n· - Class and 0 ]]. is I (public) in The excellent outer tube condition. shows no There visible is

3-4

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ F'gure

[[ 1 Visual Non-Proprietary I nspection NEDO-33787 Information of As-Received 3 - 5 Revision - Class 0 Segment I (Public) 9 (SIN ]] 0166CBT)

Figure 1 Visual Inspection of As-Received Segment 9 (S/N 0166CBT)

3-5

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) [[ Figure 11 2 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3-6 Revision - Class 0 Segment I (Public) ]] 9 (SIN 0166CBT)

Figure 2 Visual Inspection of As-Received Segment 9 (S/N 0166CBT)

3-6

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ Figure

[1 3 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3-7 Revision - Class 0 Segment I (Public) 9 (SIN ]] 0166CBT)

Figure 3 Visual Inspection of As-Received Segment 9 (S/N 0166CBT)

3-7

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) [[ Figure [[ 4 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3-8 Revision - Class 0 Segment I (Public) 6 (SIN 0327CBT) ]]

Figure 4 Visual Inspection of As-Received Segment 6 (S/N 0327CBT)

3-8

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ F igure 11 5 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3-9 Revision - Class 0 Segment I (Public) ]] 6 (SIN 0327CBT)

Figure 5 Visual Inspection of As-Received Segment 6 (S/N 0327CBT)

3-9

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) [[ Figure 11 6 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3 - 10 Revision - Class 0 Segment I (Public) 6 (SIN ]] 0327CBT)

Figure 6 Visual Inspection of As-Received Segment 6 (S/N 0327CBT)

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NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ Figure

11 7 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3 - 11 Revision - Class 0 Segment I (Public) 3 (SIN ]] 0315CBT)

Figure 7 Visual Inspection of As-Received Segment 3 (S/N 0315CBT)

3-11

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) [[ Figure 1[ 8 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3-12 Revision - Class 0 Segment I (Public) 2 (SIN ]] 0436CBT)

Figure 8 Visual Inspection of As-Received Segment 2 (S/N 0436CBT)

3-12

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ Figure C[ 9 Visual Non-Proprietary Inspection NEDO-33787 Information of As-Received 3 - 13 Revision - Class Segment 0 I (Public) 2 ]] (SIN 0436CBT)

Figure 9 Visual Inspection of As-Received Segment 2 (S/N 0436CBT)

3-13

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ Figure 11 10 Visual N on-Proprietary Inspection NEDO-33787 Information of As-Received 3 - 14 Revision - Class 0 Segment I (Public) 2 (SIN ]] 0436CBT)

Figure 10 Visual Inspection of As-Received Segment 2 (SIN 0436CBT)

3-14

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 11 [[ Visual Inspection Non-Proprietary

Serial Number 0166CBT of NEDO-33787

Inner Segment 9

Vial 65824 Information ]] Surfaces 3 - 15 Revision [II of -

Serial Number 0327CBT Class Outer

Segment 6 0 Vial Vial Vial Segment Serial Serial Segment Serial Segment I (Public) Tubes Vial 65825 65824 65826 65825 Nwnber Number Number 9 2 6 from 0166CBT 0436CBT 0327CBT Segments Serial Number 0436CBT Segment 2 Vial 65826 2, 6, and 11 9

Figure 11 Visual Inspection of Inner Surfaces of Outer Tubes from Segments 2, 6, and 9

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ Fig~re 12 Visual Non-Proprietary Inspection

Serial Number 0166CBT NEDO-33787

of Segment 9 Capsule Information 3 - 16 Centering Revision -

Serial Number 0327CBT Class 0

Pegs Segment 6 I (Public) ]] from Segment Serial Serial Serial Segment Segment Segments Number Number Number 9 6 2 Serial Number 0436CBT 2, 0327CBT 0166CBT 0436CBT Segment 2 6, and 9

Figure 12 Visual Inspection of Capsule Centering Pegs from Segments 2, 6, and 9

[[ NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 13 Visual Non-Proprietary Inspection

0166CBT NEDO-33787 Seg. 9 of Information Inner 3 - 17 Revision 11 Capsules -

0327CBT Class

Seg. 6 0 from I (Public) Segments 2, ]] 0436CBT 6,

and Seg. 2 9 O166CBT 0436CBT 0327CBT Seg.2 Seg.9 Seg.6

Figure 13 Visual Inspection of Inner Capsules from Segments 2, 6, and 9

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure [[ 14 Visual Non-Proprietary Inspection 0166CBT Segment 9 NEDO-33787 Information of Inner 3-18 Revision Capsules

0327CBT - Class

Segment 6 0 from I (Public) ]] Segments O166CBT 0327CBT 0436CBT Segment Segment Segment

2,6, 0436CBT Segment 2 and 9 6 2 9

Figure 14 Visual Inspection of Inner Capsules from Segments 2, 6, and 9

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 15 Visual [[ Inspection Non-Proprietary NEDO-33787 of Serial Number 0166CBT Inner

Segment 9 Information Surfaces and Vial 65831 3 - 19 9 Revision ]] - Vial Vial Segment Vial Segment Segment Serial Serial Serial of Class Inner 65828 65831 65834 Serial Number 0327CBT 0 Number Number Number I 9 2 6 (Public) Capsules Segment 6 0436CBT 0327CBT Vial 65834 0166CBT from Segments Serial Number 0436CBT Segment 2

2, Vial 65828 6,

Figure 15 Visual Inspection of Inner Surfaces of Inner Capsules from Segments 2, 6, and 9

3-19

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) [[ Figure 16 Non-Proprietary Extraction NEDO-33787 of

[1 Targets Information 3-20 Utilizing Revision - Class Canister 0 I (~ublic) Extraction Tool Extraction ]]

Figure 16 Extraction of Targets Utilizing Canister Extraction Tool

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 17 [[ Visual N on-Proprietary Inspection

Serial Number 0166CBT NEDO-33787 Segment 9 of Information Extracted 3 - 21 ]] Revision Serial Segment Serial Serial Segment Segment Targets -

Serial Number 0327CBT Class Number 0 Segment 6 Number Number I 2 9 6 from (public) 0436CBT 0327CBT 0166CBT Segments

Serial Number 0436CBT 2,

6, Segment 2 and 9

Figure 17 Visual Inspection of Extracted Targets from Segments 2, 6, and 9

3-21

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) [[ Figure 18 Non-Proprietary Visual

Inspection Serial Number 0166CBT NEDO-33787 Segment 9 Information of 3-22 Canisters Revision -

Serial Number 0327CBT Class from

Segment 6 0 I (Public) Segments ]] Serial Segment Serial Segment Serial Segment 2, Number Number Number 6, Serial Number 0436CBT 2 6 9 and Segment 2 9 0436CBT 0327CBT 0166CBT

Figure 18 Visual Inspection of Canisters from Segments 2, 6, and 9

3-22

[[ NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 19

11 N on- Stuck Proprietary NEDO-33787 Target Information in 3-23 CanIster Revision . - Class from 0 I Segment (Public) 0166CBT

11 ]] Figure 19 Stuck Target in Canister from Segment 0166CBT

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 20 Calibration Magnifications; Non-Proprietary Scale at 13.5X NEDO-33787 Smallest OBJ, Information Original 61 3-24 mm Division Revision Magnifications BD, - Class 500X is 0 20 I (Public) Microns of 100, 250, and 500X

13.5X OBJ, 61 mm BD, 500X Figure 20 Calibration Scale at Original Magnifications of 100, 250, and 500X Magnifications; Smallest Division is 20 Microns

3-24

NEDO-33787 Revision 0

Non-Proprietary Information - Class I (Public) [[ Figure 21 Showing Polished [[ Non-Proprietary Metallographic NEDO-33787 Information Cross-Sections 3-25 Revision - Class

[[ 0 I from (Public) Segment 6 Outer ]] Tube ]]

Figure 21 Polished Metallographic Cross-Sections from Segment 6 Outer Tube Showing [[ 11

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 22 Etched Metallographic Non-Proprietary [[ [[ NEDO-33787 Cross-Section Infonnation 3 - 26 Revision - ]] from Class 0 Segment I ]] (Public) 6 Outer 11 Tube Figure 22 Etched Metallographic Cross-Section from Segment 6 Outer Tube Showing [[ Showing 11

NEDO-33787 Revision 0 Figure Non-Proprietary Information - Class I (Public) [ [ 23 Polished MetaUographic Non-Proprietary NEDO-33787 [[ Cross-Sections Information 3 - 27 Revision ]] - Class from ]] 0 I Segment (Public) 9 Inner Tube Showing

Figure 23 Polished Metallographic Cross-Sections from Segment 9 Inner Tube Showing 11 11

3-27

NEDO-33787 Revision 0

Non-Proprietary InformationFigure - Class I (Public) 24 Polished [[ Metallographic Non-Proprietary NEDO-33787 [[ Cross-Sections Infonnation Revision - Class from ]] 0 I Segment (Public) ]] 9

[[ Inner ]1 Tube

Figure 24 Polished Metallographic Cross-SectionsShowing from Segment 9 Inner Tube Showing [[ 11

3-28

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) Figure 25 Etched MetaUographic Non-Proprietary [[ [[ NEDO-33787 [[ Cross-Section Information 3 - 29 Revision ]] - Class from 0 I Segment ]] (Public) 9 Inner Tube 1] Showing

Figure 25 Etched Metallographic Cross-Section from Segment 9 Inner Tube Showing [[ 11

NEDO-33787 Revision 0 Non-Proprietary Information - Class I (Public) The the been isotope irradiation · examination • • • • • • • nine examined General The the the No noticeable The The the As expected, metallic connector [[ The Spacer segment end Overall, [[ irradiation; 4. SUMMARY AND CONCLUSIONS rod segments targets outer contact cycle of features [[ inner exhibited The nine segments comprising a single GE14i segmented isotope rod (JYK690rod [[ ]]) have life. contact in waterside unoxidized (#9) include the segments ]], been examined in the GEH hot cells to ascertaintube their integrity and design functionality after one in centering surface the did wear no which comprising ]]. the

irradiation cycle in the Clinton BWR. The examination confirmedwere that the GE14i segmented GE14i superficial exhibited or GEH wear not mechanical excellent wear isotope rod exhibited excellent mechanical integrity and performed as intended. Highlights[[ of Clinton is 4. between the Non-Proprietary examined accelerate Zircaloy of is

the examination include the following: normal. maintained was pegs. hot appearance SUMMARY following: exhibits marks near • the

General waterside Zircaloy cladding corrosion (oxide thickness)[[ was about [[ cells a mechanical observed wear BWR. inner the the ]], which is near the detection limit of the measurement technique that was used. single design cladding were NEDO-33787 by corrosion to The [[ cladding ]]. The presence of detection fully was their capsule optical ascertain on the targets did not accelerate corrosion in any manner. ]] GE14i The observed, aspects between Information of observed the ]] satisfactory AND corrosion integrity • [[ physical ]] of the inner tube is consistent with as-fabricated levelsthe of examination surfaces inside in microscopy 4-1 limit exhibited the

[[ ]]. [[ ]] of the outer tube is [[ ]]. segmented inner their any require Revision the CONCLUSIONS outer which • Spacer contact wear marks were observed, whichbetween is a normal occurrence. The extent of of of manner. and integrity integrity (oxide - tube cladding of the contact wear is normal. the the mechanical Class re-examination tube a the performed is measurement that confirmed three isotope is

• [[

The rod segments maintained their physical integrity as demonstrated by the lustrous, 0 the a thickness) inner consistent is metallic unoxidized appearance on the inside of the three segments that were opened. I normal showed and as (Public) surfaces [[ inner segments ]]. demonstrated

• capsule The inner surface of the inner capsule exhibited a [[ ]] and one rod design functionality integrity as

segment (#9) exhibited [[ that

capsule ]] on the inner surface. occurrence. (NK690 them was with intended. technique after The features were examined by optical microscopyof that showed them to be [[ ]] that the and the about on ]].

to ]]. as-fabricated the after ]]. and GE14i were canister. inner be • the

As expected, superficial wear was observed between the inner capsule andby male threaded The [[ next . [[ [[ male that The inner Highlights

connector centering pegs. one the opened. capsule presence ]] segmented cycle was extent

• after

No noticeable wear was observed between the claddingthreaded surfaces of the inner capsule and cycle lustrous, and ]]) surface.

the outer tube or between the cladding surfaces of the inner capsule and canister. levels used. have or and one one of of of of • Overall, the GE14i exhibits fullyat satisfactory mechanical integrity after one cycle of irradiation; no mechanical design aspects require re-examination after the next cycle or at end of life. Clinton GE14i Pin-by-Pin ATTACHMENT Non-Proprietary Gamma 4 Scan ATTACHMENT 4 Report

Clinton GE14i Pin-by-Pin Gamma Scan Report

Non-Proprietary

GlobalGE14i Nuclear Fuel Global Nuclear Fuel

A Jam Vef"Wwof GETodxa H ihchi Global Pin-by-Pin Nuclear

NEDO-33784Non-Proprietary Copyright

Revision 0 Fuel DRF Section 0000-0153-6562 RO December

2012 October 2012 Global All Information Gamma Rights Nuclear

Reserved Non-Proprietary Information - Class I (Public) Fuel- - 2011 Class Global DRF Americas, Scan I (Public) Section

GE14iLL Pin-by-Pin Gamma Scan at Clinton C Nuclear at December 2011 0000-0153-6562 Clinton NEDO-33784 October Revision Fuel 2012 RO 0

NEDO-33784 Revision 0 proprietary This indicated purpose unauthorized The the Non-Proprietary Information - Class I (Public) completeness, purpose(s) design, is IMPORT a other by INFORMATION NOTICE non-proprietary engineering, information an use,

This is a non-proprietary version of the document NEDC-33784P, Revision 0, whichaccuracy, has the than stated open proprietary information removed. Portions of the document that have been removed are ANT GNF

]]. that

indicated by an open and closed bracket as shown here [[ and in NOTICE makes or Non-Proprietary the and closed removed. for version usefulness transmittal other

IMPORTANT NOTICE REGARDING THE CONTENTS OF THIS REPORT which no PLEASE bracket REGARDING

PLEASE READ CAREFULLY INFORMATION representation of information NEDO-33784 it Portions the

The design, engineering, and other information contained in this document is furnished solelyof for is as letter. the purpose(s) stated in the transmittal letter. The use of this information by anyonethe for any Information READ document intended shown

purpose other than that for which it is intended is not authorized; and with respectinformation to any of unauthorized use, GNF makes no representation or warranty, and assumes no liability as to the contained 11 The use The THE CAREFULLY or here Revision completeness, accuracy, or usefulness of the information contained in this document. the is warranty, NEDC-33784P, NOTICE - not CONTENTS [[ document Class contained of in authorized; 0 this this I and (Public) document information that assumes in ]]. OF Revision this have and THIS document. is no with furnished been by 0, liability REPORT anyone respect which removed solely as has for to to any any the are the for

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) 4. Abstract 9. 2. Acronyms 6. 3. 7. 8. 5. 10. 11. 1. Types Introduction BA Fuel Clinton Gamma Traditional Plant Comparisons References Conclusions 2.2 2.1 4.2 4.1 6.4 6.3 6.1 9.2 9.1 8.1 5.1 6.2 1.2 1.1 140 Description Pin Bundle Water Off-Line Overview Gamma LA Location Predictions Power Off-Line Description Summary Summary Scope

TABLE OF CONTENTS ...... / of LA Cycle and Scan 140 Comparisons Nodal, I40 Basis Reference of ...... Submersible Abbreviations Rod NK690 ...... of Equipment Scan Pin

Acronyms and Abbreviations ...... 13 Measurements TIP of Core Vi ...... - Plot Predicted ...... Rod, Measurements ...... of Operation for Bundle Bundle Abstract ...... Nodal, vii Comparisons Measurements Pin- of Tracking Gamma and ...... Non-Proprietary Rod 1. Introduction ...... 1-1 Pin by-Pin . Gamma ...... and Rod, JYK690 NK690 BA 1.1 Overview ...... Axial 1-1 Nodal ...... Measurements ......

1.2 Gamma Scan Measurements...... 1-1 Program Scan ...... 140 . and TABLE ... and Ba .. (BA Average ...... Distributions 2. NEDO-33784 Plant Description ...... 2-1 . RMS Spectrometer ...... TIP - 140 . Axial Comparisons ...... Traditional ......

2.1 Bundle JYK690 ...... 14o 2-1 with Description Comparisons . Infonnation ......

2.2 Location of Bundle JYK690 ...... / 2-2 OF LA Average Statistical ...... PANACII ' ...... 3. Fuel Description ...... 3-1 .. 140 iii . . CONTENTS ...... ) ...... Revision . 4. Clinton Cycle 13 Operation ...... Basis 4-1 ...... Root 4.1 Off-Line Core Tracking and TIP Comparisons ...... 4-3 - Summary ...... Class Non-Adapted ..... 4.2 Off-Line TIP Comparisons ...... 4-3 ...... Mean ...... ' ...... 0 . 5. Comparisons of Predicted...... BA140 Distributions ...... 5-1 I . (Public) ...... ' Square ...... 5.1 Predictions of Pin-by-Pin Ba14° with PANACI...... I Non-Adapted Core Tracking ...... 5-1 ...... 6. Gamma Scan Equipment and Program Description ......

...... 6-1 ...... Core ...... 6.1 Water Submersible Gamma SpectrometerComparisons ...... 6-2 ...... 6.2 Scope of Measurements ...... 6-3 . Tracking . .. (BA14° / LA140) ...... 6-4 ......

6.3 Power Rod Measurements ...... 6.4 LA14° Reference Rod Measurements ...... 6-5 ...... 7. Types of Comparisons ...... 7-1 ......

8. Traditional Basis for Gamma.... Scan Comparisons ...... 8-1 ...... ' 11-1 8.1 Summary - Bundle JYK69010-1 - Traditional Basis ...... 8-1 . 9-2 2-1 4-3 4-3 4-1 8-1 5-1 6-4 6-1 6-3 6-2 9-1 9-1 7-1 2-2 2-1 8-1 3-1 6-5 5-1 1-1 1-1 1-1 vii 9. BA140 / LA140 Pin Nodal, Rod, and Axial Average Root Mean Square Comparisons ...... 9-1 vi 9.1 Pin Nodal, Rod, and Axial Average Statistical Summary ...... 9-1 9.2 Summary Plot of Pin Nodal RMS ...... 9-2

10. Conclusions ...... 10-1 11. References ...... 11-1

NEDO-33784 Revision 0 Figure Figure Figure Figure Figure Figure Figure Figure Figure Non-Proprietary Information - Class I (Public) Figure Figure Figure Figure

LIST OF FIGURES 4-3 4-2 3-1 2-1 4-1 6-1 6-5 6-3 6-2 3-2 5-1 6-4 9-1

Figure 2-1 TIP Locations for Clinton ...... 2-2 Locations Predicted TIP TIP Total Description Reference Average Components Core Cycle Rod Pin Cycle Figure 3-1 Description of Bundle 3243 - JYK690 ...... [[ 3-1 Nodal Locations Machine in GE14i Bundle (Candle Stick) ...... 3-2 Types Figure 3-2 Rod Types Power % Exposure 13

-Line Core Tracking vs.]] Core Power and Notches Inserted Cycle 13 Off Rated

Figure 4-1 Axial Off-Line Inch Pin-by-Pin of Comparisons Rod in Cycle Exposure ...... 4-2 Non-Proprietary of and Gamma of Assignments for GE14i for La % Rated Flow and Notches Inserted Bundle Core Figure 4-2 Total % Rated Core Power and Values Measurements the ...... Notches

Cycle 13 Off-Line Core Tracking vs. Date ...... 140 4-2 Clinton Core Water Power Measurements

...... 4-4 Bundle

4-3 TIP Machine Assignments for Clinton Ba

Figure Scanned NEDO-33784 LIST OF 3243 for

5-1 140 Tracking Figure 5-1 Predicted Pin-by-Pin Ba'40 Distributions - Non-Adapted ...... for Inserted Reference Submersible ...... Distributions 6-1 and ...... Non-Adapted -

Figure 6-1 Components of the Water Submersible Gamma Spectrometer Information (Candle JYK690 Rods Rod Clinton

Figure 6-2 Locations of Gamma Scanned Rods ...... 6-3 % vs. Cycle Rated iv ]] ...... 6-5 FIGURES

Figure 6-3 Reference Rod Measurements Rod [[ [[ for ...... Rod Revision Date Stick)

]] ...... 6-6 ......

Figure 6-4 Average Axial Values for Reference Rod [[ ...... Rod Gamma 13 Flow - -

]] ...... 6-7[[ Case -5 [[ ]] Inch La 140 Measurements for Rod [[ ]] Figure 6 ...... Non-Adapted Class Off-Line ...... [ ]] [[ Figure 9-1 Pin Nodal Comparisons for Non-Adapted Case - Nodes [[ ]] ...... 9-2 0 and - Spectrometer ]] I Nodes (public) Notches ...... Core ...... [[ ...... Tracking ...... Inserted ...... ]] vs...... 4-2 6-3 2-2 4-2 4-4 5-1 6-1 6-6 6-5 9-2 3-1 6- 3-2 7

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) Table Table Table Table Table Table Table

LIST OF TABLES 9-1 4-1 2-1 4-2 8-2 8-1 10-1 Table 2-1 Gamma Scan Bundle Location in Cycle 13 ...... 2-1 Pin Comparison Gamma Bundle Results Table 4-1 Bundle Inventory Cycle 13 ...... 4-1 Statistical Summary

Table 4-2 Summary of TIP Statistics Non-Adapted Offline PANACI I ...... 4-5 Nodal, Table 8-1 Statistical Comparisons Using the Traditional Basis Non -Adapted Off-Line ...... 8-1 Inventory for Scan of Comparisons

Table 8-2 Results for Non-Adapted Rod

Off-Line ...... 8-2 Non-Adapted Non-Proprietary of TIP

Table 9-1 Pin Nodal, Rod and Axial Averaged RMS Comparisons ...... 9-1 Bundle Traditional and Statistics

Table 10- 1 Comparison of Traditional Statistics for Gamma Scan Measurements ...... 10-1 Cycle Axial Location NEDO-33784 LIST Using 13 Off-Line Averaged Non-Adapted Statistics ...... Information OF the in Cycle Traditional v ...... TABLES RMS for Revision Gamma 13 - Offline Comparisons Class ...... Basis 0 Scan PANAC11 I (Public) Non-Adapted Measurements ...... Off-Line ...... 10-1 2-1 9-1 4-1 4-5 8-2 8-1

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) Term BOC LPRM EOC BWR GNF CALTIP HPGe RP PLR BAZ OIEP GEH GE CYCEXP TIP RMS PCTIP DAS WCT VAD VABS IAT WSGS Acronyms and Abbreviations ----

Term Definition ------

BAZ Bottom of the Active Zone ------Definition GE Root High End Beginning Boiling Variable Global Calibrated Cycle Traversing Reactor Bottom Data Part Process General Core Operational Bundle Variable Local BOC BeginningWater of Cycle -.--- -~ Hitachi of Length - Acquisition Flow Mean BWR Boiling Water Reactor Purity Non-Proprietary Exposure Power Submersible Cycle Nuclear Number Water of ---- Computer Power Electric --- Absorber Aperture the Traversing CALTIP Calibrated Traversing In-Core Probe of in In-Core Nuclear Square Rod Germanium Information - Range Cycle Mlbmlhr Active Reactor

CYCEXP Cycle Exposure Fuel - System - Acronyms Device Traversing Section NEDO-33784 - Probe Gamma - Monitor Energy

DAS Data Acquisition System Zone In-Core Exchange Information

EOC End of-.- Cycle Spectrometer In-Core Probe

General Electric and

GE ,. VI Provision Revision ---

GEH GE Hitachi Nuclear Energy Abbreviations Probe - GNF Global Nuclear Fuel -- Class -- --- 0

HPGe High-- Purity Germanium - I -- IAT Bundle Number (Public) --- LPRM Local Power Range Monitor - OIEP Operational Information Exchange Provision ------PCTIP Process Computer Traversing In-Core Probe

PLR Part Length Rod ------

RMS Root Mean Square - - RP Reactor Power --

TIP Traversing In-Core Probe

VABS Variable Absorber Section

VAD Variable Aperture Device

WCT Core Flow in Mlbm/hr

WSGS Water Submersible Gamma Spectrometer

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) between U02 P ANAC validates and fuel deviation 2011 Gamma in nuclear rods at the scanning 11 Abstract designs the the of allow fuel. boiling Gamma scanning is a non-destructive method to determine the relative fission product inventory Clinton measurements applicability [[ in nuclear fuel. A pin-by-pin gamma scan on a GE14i 10x10 fuel assembly was completed in for A comparison 2011 at the Clinton Power Station at the end of Cycle 13. Measurements of La140 from Gad and is pin-by-pin water Power the a

U02 rods allow comparison of relative predicted and measured pin powers. The agreement non-destructive GE14i Non-Proprietary

between the measurements and predictions using the TGBLA06 lattice physics code and the ]] reactor of Station for

PANAC 11 boiling water reactor (BWR) core simulator is adequate, with a corrected standard and lattice of bundle deviation of [[ ]] for Ba14° / La140 using the traditional comparison basis. The data gamma Ba relative predictions (BWR)

validates the applicability of lattice power distribution uncertainties used for modem BWR core at 140 NEDO-33784 power

and fuel designs for the GE14i bundle designs. the / method designs. scan La end rdce and predicted Information core 140 distribution Abstract on using of using to vii simulator a Cycle determine GE14i Revision the the - 13. uncertainties TGBLA06 traditional Class measured 10x10 is Measurements 0 the adequate, I relative (Public) fuel pin comparison lattice used assembly with powers. fission for of physics a La modem corrected was product 140 basis. The from code completed BWR agreement inventory The standard Gad and core data and the in

vii

NEDO-33784 Revision 0 be nuclear bundles beginning The La Power pin-by-pin bundle possible detector. can Thus, Power half-life was performing form 60 of and and accompanies once-burnt distribution Gamma isotope 1. technique spent from for 1.1

Non-Proprietary Information - Class I (Public)1.2 10 140 made interest Introduction - days further also Overview individual decays Gamma 120 shipped subject of the is 1. Introduction fuel the Station distribution JYK690 rod fuel. traversing an following scan surroundin~ be days after of on beta

1.1 Overview scan pool For of for examination. gamma are independent, GE14i applied with the [[ Ba either of or to beta Scan programs cycle of core Gamma decay

Power distribution validation data for operating boilingmeasurements water reactors is routinely taken in the potentially in normally 140 fuel results for measurement, . the this reactor integrated the

form of traversing in-core probe (TIP) measurements. In this case, the average power of the fourDecember decay also bundle This reactor in-core bundle scan Measurements measurement. shutdown, validation for pins 13 GE

bundles surrounding the instrument tube isBa detected via a neutron sensitive or gamma sensitive document of the can scan (BOCI3). measuring makes vary 140

For potentially greater resolution and at greater effort and cost, gamma scanningbundle of detector. measurements Hitachi operation. the transferred reinserted of non-destructive Non-Proprietary instrument average shutdown, probe greater was half-life. La140 is an independent, non-destructivebe method to determine the relative power distributions in La measurements fission of power by used nuclear fuel. Gamma scan measurements for the purposeof of power distribution validation may J40 data measuring usually it re-Ioaded 2011 ]] was specification is Nuclear (TIP) "power" imperative be made on either bundle average or pin-by-pin measurements.with The gamma scanning techniques replaced the resolution or For The pin-by-pin to for for NEDO-33784 product to

can also be applied for measuring the relative exposures (Cs137) a history tube pin-by-pin The at La relative determine GE14i a during measurements. the the for fuel operating additional the 140 The subject of this document is pin-by-pin gammahalf-life scan measurements made at the Clinton method Energy into Ba time, is Information power water gamma calls with atom for end Power Station in December of 2011 at the end of cycle 13 (EOC13). One bundleassembly was scanned, Ba detected J40 that and over of refueling exposures (Reference the gamma the 1-1

bundle JYK690. This bundle was a GE14i (Reference140 1) once-burnt fuel assembly loaded at and distribution of the a measurements. for density "recent" of submersible distributions (GEH) to boiling the at new use beginning of cycle 13 (BOC 13). For the gamma scan, the bundle upper tiecore plate was removed Revision that cycle purpose scan, the 40.2 physical number determine greater and individual fuel pins transferred to the water submersibledetection gamma spectrometer located in the via · was gamma - segmented In scan has during operations, Reference last Class spent fuel pool for measurement. The fuel assembly was then reassembled, with one segmented (Cs is hours. the 13 Vallecitos a water this core 1) then proportional neutron isotope rod [[ ]] replaced with aa new segmented isotope rod. Subsequently, the of 0 in 137 (EOCI3). effort of measurements bundle locality once-bumt half-life five

gamma ]] case, scan I (Ba ). the power once-burnt GE14i bundle was re-loaded intofuel the core during the outage, [[ of the power reassembled, measurements. reactors (Public) La was shipped to the GE Hitachi Nuclear Energy (GEH) Vallecitos Nuclear Center in California The the 140 isotope outage, 2 relative and J40 half-lives, because is data the sensitive Nuclear upper summarizes of for further examination. gamma / distribution characteristic spectrometer accumulates distribution. of 1.6 La One average cost, the to is fuel be 140).

1.2 Gamma Scan Measurements 12.8 rod. MeV the [[ tie power routinely measurement, made bundles collected bundle Center with scanning gamma or Gamma scan programs vary by specification of the physical locality of the measurement, timeassembly of plate Ba days. or Subsequently, power For gamma

performing the measurement, measuring time, and numbergamma of measurements. For example, the 140 the distributions validation one at approximately in located The was of technique for measurements of "power" calls for detection of the 1.6 MeV gamma ray thatwas example, atom in with taken most scanning After the fuel as techniques segmented of the

accompanies beta decay of La140 with a half-life of 40.2 hours. La14° accumulatesCalifornia in fuel mainly loaded removed sensitive scanned, 12.8 ray the soon Clinton powers density time

from the beta decay of the fission product Ba140 thatmainly has a half-life of 12.8 days. After about fission recent in in about may 10 days following reactor shutdown, La140 atom density is proportional to the Ba'40 atom density four that day the the the the as of of in at and decays with the Ba'40 half-life. The Ba140 distribution in fuel is characteristic]] of the fission distribution or integrated power history over the last five half-lives, or approximately 60 - 120 days of reactor operation. Thus, the scan results can be used to determine "recent" core power distribution. The 12.8 day half-life of Ba140 also makes it imperative that the gamma scan data be collected as soon as possible after core shutdown, usually during refueling operations, because bundles with powers of interest are normally reinserted for additional use. Reference 2 summarizes the most recent pin-by-pin gamma scan measurements for power distributions (Ba14° / La'40)

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) 2. More official3DMTM The Table 2.1 Reference JYK690 the following scanned, Note: 1. Bundle m Plant IA completion Bundle

2. Plant Description gamma T: information 2-1 Bundle IAT

2.1 Bundle JYK690 Type Description and [[ summarizes 1. sections. (1) JYK690 The gamma scanned bundle was a GE14i once-burnt fuel assembly originally loaded at BOC13. scanned Number then PANACl1

Table 2-1 summarizes general information regarding the bundle that was disassembled, gamma of Table reassembled. regarding

scanned, and then reassembled. The once-burnt bundle JYK690 was reinserted into the core at the bundle the completion of the gamma scan measurements. The EOC exposures are taken from the For general gamma Non-Proprietary official 3DMTM PANAC11 wrap-up from the site. 2-1 more wrap-up was Bundle

More information regarding the bundle design and history for this bundle is provided in the the information scan detailed

following sections. The For more detailed information regarding the GE14i bundle design, see a Gamma ude design bundle GE14i Name Reference 1. NEDO-33784 from measurements. once-burnt Table 2-1 Gamma Scan Bundle Location in Cycle 13 information Information the once-burnt Scan

Cycle 13 Cycle 13 regarding

EOC13 site. Bundle IAT Location Location EOC13 2 Bundle Name Exposure Exposure Bundle - ID Type Site PANACEA 1 and bundle Coordinates Coordinates GWd/ST GWd/MT Revision history fuel the JYK690 [[ - regarding ]] The Coordinates Class Location Location Cycle JYK690 bundle assembly Note: Site 0 O exposures EOC 13 for 1. IAT: Bundle Number I (Public) the that this was in Coordinates PANACEA originally Location Cycle Cycle GE14i was bundle reinserted 13 disassemb~ed, 13 are bundle is loaded Exposure GWdlST O1 EOC13 EOC13 provided taken into design, at the from BOCI3. gamma GWdIMT Exposure core in see the the at ]]

NEDO-33784 Revision 0 instrument 2.2 outline. identified Figure with in Non-Proprietary Information - Class I (Public) [[ green Location 2.2 Location of Bundle JYK690 the 2-1 TIP in The

Figure 2-1 provides the locations of the TIP strings in Clinton, with each TIP instrument tube by tube. provides this the identified by the TIP string number. The location of the bundle scanned in Cycle 13 is identified string TIP of

in green in this figure. The TIP string is located at the bottom, right hand corner of the bundle figure. TIP Bundle locations

with the TIP string number. The locations of the Sequence A-2 control rods are marked in a red number. the outline. The TIP locations do not change between cycles. Note that JYK690 is adjacent to an string The locations Non-Proprietary instrument tube. JYK690 Figure number. do TIP 11 The not string locations of 2-1 change NEDO-33784 The the is location TIP Information TIP located between of the strings Locations 2 - 2 Sequence Revision at of cycles. the the in - Class bottom, bundle Clinton, for 0 A-2 Note Clinton I (Public) scanned control right with that hand each JYK690 rods in Cycle comer TIP are is instrument marked 13 adjacent of is the identified in bundle to a tube red an ]]

11 Figure 2-1 TIP Locations for Clinton

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) 3. natural The Gad [[ Fuel GE14i rod, enrichment 3. Fuel Description Description however,

The GE14i bundle loaded into Clinton has a 150 inch active fuel length, with [[ ]] inches of bundle loaded natural enrichment at the top and bottom of the U02 rods, as seen in Figures 3-1 and 3-2. The only

Gad rod, however, only has an active length of [[ ]] inches. at Figure the

[[ has Non-Proprietary top into an 3-1 and Clinton active bottom NEDO-33784 Description length has Information of a of 150 the 3-1 [[ of U0 inch Revision Bundle 2 active rods, - ]] Class inches. 3243 0 as fuel1ength, I seen (Public) - JYK690 in Figures with [[ 3-1 and ]] 3-2. inches ]] The of

]] Figure 3-1 Description of Bundle 3243 - JYK690

3-1 NEDO-33784 Revision 0

Non-Proprietary Information - Class I (Public) [[

11 Figure Non-Proprietary 3-2 Rod NEDO-33784 Types Information in 3-2 GE14i Revision - Bundle Class 0 I (Candle (Public) Stick) ]]

11 Figure 3-2 Rod Types in GE14i Bundle (Candle Stick)

i i I I ------NEDO-33784 Revision 0 [[ Non-Proprietary Information - Class I (Public) -- The BOC 4. blades axis. official average complete Figure off-line Clinton

4. Clinton Cycle 13 first Operation----- Figures is at 2-1. exposure .- core exposure provided

The first official exposure- accounting case for Cycle 13 started on February 8, 2010. The last Notch official operating

official exposure accounting case ended November 29, 2011. The inventory of fuel in the core at Cycle - A tracking. 4-1 - BOC is provided in Table-- 4-1. The location of bundle JYK690 in Cycle 13 is provided in series 10. .-- accounting exposure 13 of Figure 2-1. Bundle A series of [[ and

]] off-line core-tracking cases deplete the core to the cycle in cycle These - [[ average exposure of [[ Operation ------]] at EOC13. At the end of the cycle, there were two Table of - 4-2 --- .. blades at Notch 10. These control blades were located symmetrically in the core along the center From Non-Proprietary . Name - [ ]] [[ - Table control summarize axis. Figures 4-1 and 4-2 summarize the Cycle 13 plant operation, as derived from the official accounting 4-1. case ------off-line core tracking. From Figure 4-2, it is apparent that there were no outages during this Figure ------+------~--~~-----+------~---- 4-1

complete operating cycle. ended The blades NEDO-33784 - off-line Table 4-1 Bundle Inventory Cycle 13 4-2, the - case location - November - - - Bundle were Information ]] Cycle Bundle Name #in # AvgWt AvgExp it 1 IAT for at is - Core Fresh KG GWd/ST core-tracking 4-1 located EOCI3. -- apparent Cycle of -.- 13 Inventory Revision 29, bundle plant ~- - 13 symmetrically 2011. fAT Class . At --- that started operation, JYK690 0 the cases Cycle there The inventory The I -- (Public) end --- Core #in on deplete 13 were of February in as - in -- the Cycle derived the - - - no Fresh cycle, the # core of --- - outages - 8, - 13 core fuel from - along \--- ~- 2010. there is AvgWt - in . KG to - provided the during - the the were the - The -~ ----r official core center cycle GWdlST ----i AvgExp two this last -- in at - ~ ~

NEDO-33784 Revision 0 [[ Non-Proprietary Information - Class I (Public) Figure Figure

11 4-1 4-2 [[ Core Total Power Non-Proprietary % Cycle and Rated 13 Notches NEDO-33784 Core Off-Line Power Information Inserted Exposure Core 4 - 2 and Revision Cycle Tracking % - Class Rated

13 11 0

Cycle 13 Off-Line CoreOff-Line Tracking vs. Cycle vs. Figure 4-1 Core Power and Notches Inserted I (Public) Flow Exposure Date

[[ and Core Notches Tracking ]] ]] Inserted vs. Cyc : le .

]J Figure 4-2 Total % Rated Core Power and % Rated Flow and Notches Inserted Cycle 13 Off-Line Core Tracking vs. Date

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) In but comparisons 4.1 4.2 models margin adaption. compared on-line infonnation. This TIP The Table Information 4.2.1 4.2.2 were assignment off-line Clinton. a Figure sixteen gamma the Off-Line Off-Line the nonnal comparisons section separated TIP Off-Line 4-2. shape " 2-1 evaluations. with core different core axial "

4.1 Off-Line Core Tracking and TIPTIP Comparisons to Machine has The of off-line Exchange documents PANACll adaption the to In tracking monitoring plant, TIP The normal off-line core tracking used to maintain the Global Nuclear Fuel (GNF) / GEH core Core the shape by previously Non-Adapted " radial measured the models with PANAC 11 uses a small sub-set of the on-line 3DMTM cases that are produced in the on-line sets TIP based only Comparisons Tracking on-line on-line core monitoring process. Inbut addition, the off-line core tracking is non-adapted, as core Assignments of . process, (or string when of Provision a few compared to the on-line core tracking. In the on-line]] model, the thermal limits are modified via these the uses core Non- the on tracking process. Bundle) comparisons to measured TIP and local power range monitor (LPRM) readingsLPRM using "shape provided TIP system, off-line the to augmented a power hours. adaption." tracking. values Proprietary and the TIP small and TIP normal In the shape adaption process, the radial power calculated by the core simulator(OIEP) is not modified, calibration radial used root TIP NEDO-33784 Comparisons these machines. TIP local the In distribution are but the axial shape of the power distribution is modified using the plant TIP and LPRM sub-set mean Comparisons addition, In to

information. In the on-line system, these modified power distributionslocation are used only for thermal comparisons derived comparisons reasonable off-line power with data modified Infonnation power the margin evaluations. maintain of square data transmittals on-line retrieval 4-3 The 4.2 Off-Line TIP Comparisons the calculated of range non is the Revision 0 on-line power obtained for common This section documents the off-line TIP comparisons derived from thethe inputs used in the normal the modified (RMS) -adapted off-line - off-line core tracking when augmented with retrieval of the measured TIP data. There were model, a monitor of 33 Global Class thennal

sixteen different sets of LPRM calibration data obtained from the site via the Operational distributions from by the 3DMTM TIP is channel Information Exchange Provision (OIEP) data transmittals from Clinton to GNF.from Some of these the the from I core using core larger measured (Public) Nuclear strings. Clinton

were separated by only a few hours. (LPRM) TIP thennallimits core cases the the tracking 4.2.1 TIP Machine Assignments tracking than the is plant, simulator inputs are site at Fuel to Figure

Figure 2-1 has previously provided the location of the 33 TIP strings. Figure 4-3 provides the that TIP plant readings would location used GNF. which

assignment of the TIP string to TIP machines. The common channel is at locationvia [[ are are (GNP) is used data. TIP 4-3 are only non-adapted, the is be produced summarized Some is not [[ in using modified provides expected Operational / There and the for the

11 GEH modified, of case thennal nonnal "shape 4.2.2 Off-Line Non-Adapted TIP Comparisons LPRM in these were core via the the for for as TIP comparisons based on the normal off-linein non-adapted core tracking are summarized in Table 4-2. The radial (or Bundle) root mean square (RMS) is larger than would be expected for a gamma TIP plant, but these values are reasonable for a thermal TIP plant, which is the case for Clinton. NEDO-33784 Revision 0 [[ Non-Proprietary Information - Class I (Public) [[

11 Figure Non-Proprietary 4-3 NEDO-33784 TIP Machine Information 4-4 Assignments Revision 0 - Class I (Public) for Clinton

11 Figure 4-3 TIP Machine Assignments for Clinton ]]

4-4

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) Note: 1. Case 13 15 14 12 10 11 4 6 1 5 3 7 9 2 8 PCTIP: CYCEXP: CALTIP: wCr: Table 4-2 SummaryRP of TIP Statistics Non-Adapted Offline PANACII : Reactor Standard [[ Core

n) Table CYCEXPProcess RP(') WCT n> Case Qualifier Bundle Axial Nodal PCTIP (r) CALTIP t» Calibrated Maximum Minimum Qualifier MWd/STCycle MW(t) Mlbm/hr RMS RMS RMS Symmetry

Flow Symmetry Power Mean RMS 1 [[ - - Deviation Computer 4-2 Exposure

2 Traversing

3 Traversing Summary 4 Non-Proprietary C In-Core MWdlST 5 Y C EXp(l)

6 In-Core Probe of

7- NEDO-33784 TIP Probe 8 MW(t) RP(I)

9 Information Statistics 10 Mlbmlhr WCT(1) 4-5 11

12 Revision Non-Adapted

13 - Bundle Class [[ 14 RMS 0 15 I (Public) Axial RMS

RMS Offline Nodal RMS Mean P ANACll Symmetry Standard Deviation PCTIP

Minimum (I) CALTIP(1) Symmetry Maximum l]

Note: ]] ]] 1. CALTIP: Calibrated Traversing In-Core Probe CYCEXP: Cycle Exposure PCTIP: Process Computer Traversing In-Core Probe RP: Reactor Power W C T: Core Flow

NEDO-33784 Revision 0 the Figure 5.1 measured the 5. This Non-Proprietary Information - Class I (Public) [[ Comparlsons power experimental Predictions section 5-1 data. 5. Comparisons of Predicted BA140 Distributions gamma Figure provides

This section contains comparisons of predicted Ba140 distributions without comparison to the contains Also of data

measured data. Also note that only relative predictions are provided, with no absolute values, as of scan at 5-1 Pin- Predicted the experimental data will also only be relative measurements, not absolute values. the note wiU comparis~ns by-Pin Non-Adapted Core Tracking pin-by-pin 5.1 Predictions of Pin-by-Pin Ba140 with PANAC11 Non-Proprietary Clinton. Predicted also that Figure 5-1 provides the pin-by-pin Ba140 distributions for the [[ ]] rods measured as part of only only BA the power gamma scan at Clinton. Ba 140 140 Ba NEDO-33784 be relative of Pin-by-Pin with

[[ Distributions 140 relative measurements, predicted distributions Information PANAC11 predictions 5 - Ba 1 Ba Revision 140 140 - Non-Adapted Distributions for are distributions Class the provided, 0 I [[ not (Public) absolute - ]] without Core with Non-Adapted rods no values. Tracking measured absolute comparison values, as part to the ]] of as

]] Figure 5-1 Predicted Pin-by-Pin Ba140 Distributions - Non-Adapted

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) components The 6. individual Gamma Water

6. Gamma Scan EquipmentFigure and Program Description irradiated Scan

The Water Submersible Gamma Spectrometer (WSGS) measures gamma emissions from of Submersible the individual irradiated fuel6-1 rods in the plant spent fuel pool. Figure 6-1 identifies the various Equipment

components of the WSGS. WSGS. fuel Co Non-Proprietary Ill»onents rods Gamma and in the Program NEDO-33784 Spectrometer of plant the Information Water spent Description 6 - } Revision Submersible (WSGS) fuel - pool. Class 0 measures I Figure (Public) G.mJDIIDt~oT UJUoaEar Gamma 6-1 gamma Spectrometer identifies emissions the various from

IMB2 Pule

Lifting Clam

Figure 6-1 Components of the Water Submersible Gamma Spectrometer

NEDO-33784 Revision 0 joined Device 6.1 fuel option according The The incident opening watertight shielded leading nitrogen the the end detector To in collimator [[ measurement. to the scanning. standoff. sidewall. scanner carriage The Non-Proprietaryin Information - Class I (Public) a place brackets perform rod pool collimator Water lifting of WSGS system rod WSGS to to the through (V to called housing. and for in increases rail on lines, housing, the This Submersible Gamma Spectrometer insert The to 6.1 Water AD), lead the is The bar. assembly front Submersible is is axial the measurement. on cask detector is the attached is slit held comprised The WSGS is comprised of several components. These are a high purityassembly germanium detector, a the carriage and arrangement The and fuel attached the the The detector. assembled and absorbers application of scanning, shielded housing, an attached collimator with an installedpit. collimator slit, a Variable Aperture by an the Jaw air in detection selectedtungsten rod slit size is the curb rod lifting Device (VAD), and a Variable Absorber Section (VABS). The collimator a raising is and attached place to The number circulation Variable Clamp rail placed travels according to the application and fuel rod activities. The VAD controls the opening between the and collimator is and to Non-Proprietary the Gamma of mount. WSGS captured A system fuel rod in front of the collimator and the shield block opening at the detector. A larger VAD in bar the This the provides in by is several shielded and VAD. or the zone. data opening increases the number of gamma-rays incident on the detector. The VABS allows the the depicted the Assembly. collimator of through the lowering curb is single placing Absorber rod allows fuel

option to insert absorbers in the gamma-ray path, also controlling the number of gamma-rays assembly. held gamma-ray gamma-rays tubing spent is Spectrometer acquisition A method NEDO-33784 by components. incident on the detector. A data acquisition system (DAS) including a motion controlThe unit is inserted lowered mount the housing. rod wall rod in the the in

joined to the detector and WSGSthe assembly. the fuel a V the path place connect activities. Information Figure with carriage Section AD For grapple High standoff shield support of rod

The WSGS is assembled by placing a Highand Purity Germanium (HPGe) detector into the tungsten cask into into path, for system controlling 6-2 is

watertight lead and tungsten shielded housing. This is attached to the collimatorscanning, as in Figure 6-1. by This incident an to suspends 6-1 made Purity the through the pit block the Revision These a

[[ be (V installed is and jaws

The also curb horizontal axis. is assembly ]] opening along its . The by water ABS). top attached block completely rod ]] - (DAS) ]]. attached of placed Class on opening

collimator is attached to the VAD. The VAD is made of tungstena and controls the opening size opening are Germanium and controlling mount V the and tungsten carriage wire an the into The AD using leading to the slit by raising or lowering the tungsten block through the gamma-ray path. At the the 0 through collimator a jaw [[ umbilical The bottom including I fuel to high

end of the assembly is placed the method of controllingholds the fuel rod placement in front of the into the data cable to controls detector. (Public) clamped the at clamp a captured scanner called the Jaw Clamp Assembly. For scanning, the jaw clamp is attached toalong the end of the collimator to rod cask and crane the purity the collection the the the collimator assembly and the rod inserted universal into the top and bottom guide rollers, which directs the suspension guide travel collimator (HPGe) placement rod attached controls slit, the rod through the detection zone. detector. its the gamma-ray a pit, is number to and WSGS The motion germanium attached by carriage horizontal rollers, the opening up

The system is held in place in the spent fuel cask pit by a wire cable suspension system attached a supported slit the the Variable VABS electronics, carriage detector

to a lifting bar. The lifting bar is held inand place by a curb mount clamped to the curb surrounding curb the as to system lifting size of away A grapple in the pool and cask pit. The system is lowered into the water using a crane and the lifting bar is set control the in which to down and opening path. gamma-rays between larger surrounding front

in brackets on the curb mount. A wall standoff assembly holds the WSGS away from theFigure is detector, allows axis. the top by rail. from bar Aperture clamped into This arrangement is depicted in Figure 6-1. attached sidewall. selected directs unit during during end a At of of liquid V is wall 6-1. The The axial scanning, the single rod carriage is attached to the universal carriagesize rail. The To perform AD the the the the the the the set of into the cask pit, supported by a wall is carriage rail is attached to the curb mount and suspends a standoff. The carriage rail provides the path for the rod carriage to travel up and down during scanning. The fuel rod is captured by the grapple and placed into the rod carriage and clamped in place for measurement. This allows the rod to be completely captured by the grapple during measurement. The rod travels through the support jaws and [[ ]]. The data collection electronics, liquid nitrogen lines, and air circulation tubing connect through an umbilical attached to the top of the detector housing.

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) A The During the 6.2 6.2.1 [[ [[ [[ total measurements Scope La Measured 140 of 6.2 Scope of Measurements the [[ measurements of During the gamma scan measurements, [[ ]] fuel rods were measured. This report describes gamma Measurements the measurements and analysis for the [[ ]] fuel rods. ]] Rods and fuel 6.2.1 Measured Rods scan Figure analysis rods measurements, A total of [[ ]] fuel rods were gamma scanned, as described in Figure 6-2. Non-Proprietary started were

[[ 6-2 for on gamma the ]] NEDO-33784 [[ Locations local [[ [[ Infonnation scanned, time. ]] 6-3 ]] fuel of fuel Revision Gamma as rods. rods described - Class were 0 Scanned

]] I (Public) in measured. Figure ]]

[[ Rods ]] 6-2. and This were report describes finished on ]] ]] Figure 6-2 Locations of Gamma Scanned Rods The La140 measurements started on [[ ]] and were finished on [[ ]] local time.

NEDO-33784 Revision 0 process. process. natural power during different The zone, the measured multiple bottom 6.3 every every [[ Gad inches segmented [[ Non-Proprietary Information - Class I (Public)inches. bottom Power GE14i rod, so [[ [[ gamma starting the enrichment of ]]) ]] Measurements times as axial The however, The at

(BA14° / LA14) rod. 6.3 Power Rod Measurements the were of isotope subsequent bundle Rod to [[ the ]] ]] inchesrod of active data The GE14i bundle loaded into Clinton has a 150 inch active fuel length, with [[ heights at obtain scan ]] [ ]] [[ This inches: meas':ll'ed in Figures 3-1 and 3-2. The Measurements

inches. as seen the natural enrichment at the top and bottom of the U02 rods, active [[ loaded rod at only for

]] inches. Measurements are made atmeasurements, ]]

Gad rod, however, only has an active length of [[ fuel beginning full experimental the along inch connectors rod of this [[ different axial heights along the length of these rods. There are [[ fuel Non-Proprietary has zone. Measurements length top ]] the into

]] measured as part of this campaign. The firstevery rod measured was the inches measurements [[ reference zone measured the an and [[ ]] rod. This full length rod was chosen as the reference following rod. This rod was measured Clinton of [[ active length (BA rod . multiple times at the beginning of the gamma scan campaign, and ]] then re-measured[[ periodically bottom above on the NEDO-33784 confirmation during the subsequent rod measurements to ensure consistency of the multi-day measurementand 140 was the rod gamma has as

]]. the experimental uncertainty of the

to assess length process. The data for this reference rod is used of / also [[ for the LA axial part Information chosen of and also as a check on the accuracy of the decay correction these is to

power gamma scan measurements, a Measurements the 150 bottom 14') the as ]] inches, [[ ]] used process. The rod [[ ensure inches, of of scan 6-4 power a rods. following V02 ]]

the bottom of the active fuel zone. inch this ]] [[ of as check Revision to inches, campaign, full the of

]] segmented isotope rods) was the ]] [[ consistency campaign. assess active rods, [[ shape - There the have

]]length the bottom of the active fuel

]] inch [[ Class analytic

measured at [[ on reference ]] of [[ active zone, so as to obtain experimental confirmation of the analytic evaluations of the effect of[[ the 0 as the of fuel the inches. axial are ]]. the ]]. [[ I and rods segmented isotope rod connectors on the axial power shape of [[ seen [[ (Public) accuracy experimental

]] the [[ ]] evaluations Gad length,

]] inches, [[ The ]]) were measured every [[ fuel of ]] measurements then rod. segmented were ]] [[ ]] in

]] have axial measurements everythe

bottom of the active fuel zone. [[ the Measurements first zone: rod full ]] full length rods were made every [[ ]] Figures

inches. Measurements of the following [[ re-measured bottom with This multi-day made of length ([[ inches starting [[ ]] inches above the bottom of the active fuel zone: [[ rod [[ the

of ]]) were made

]]. Measurements of the Gad rod ([[ [[ rod uncertainty measured 3-1 isotope ]]. every of decay ]] full lengththe rods were made

Measurements for the followingrods [[ every [[ ]] inches. every ]]) was the [[ and

]]. measurement every [[ ]] inches: [[ effect are periodically [[ ]] were were active correction rods) measured 3-2. [[ inches made was of of ]] made made was The fuel the the the the of at ]] ]] ]] .

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) 6.4 The [[ The measurement relatively reproducibility" 6.4.1 Nodes collimator To For measurements. standard comparisons. [[ quantify LA measured reference this Analysis ]] [[ 6.4 LA140 140 Referencedeviation Rod Measurements axial reason, small Reference and

The measured data for this referencethese rod is shown in Figure 6-3. campaign. data detector. rod positions of differences The is

[[ Figure Reference uncertainties, these of for provided measurements first the Rod ]], this Non-Proprietary The measurements There is bottom 6-3 where item reference Measurements first in second in Rod the are is Table the computed. the Reference and the Measurements axial provide NEDO-33784 two average rod item signal axial 8 top important made - position is 2. Information is shown is nodes Rod the insight positioning The This value at the 6-5 uncertainty each Measurements contribute uncertainty Revision 0 in is items lowest, of are as Figure shown axial the - to generally Class that of [ ]] [[ the the level. the in 6-3. in to contribute is I the uncertainties flux Figure larger (Public) slice highest Rod actual The not curvature measurements of measurement 6 [ ]] [[ data to - considered the 4, count (exceeds the which for rod in uncertainties is rates. the the presented the also "measurement [[ at uncertainties. experimental in

largest, ]] each shows statistical Figure 6-3 Reference Rod Measurements Rod [[ ]] of to in 6.4.1 Analysis of ]]) Reference Rod Measurements and the the the the in The reference rod measurements provide insight as to the]] uncertainties in the experimental measurement campaign. There are two important items that contribute to the uncertainties in the measurements. The first item is the axial positioning of the slice of the rod presented to the collimator and detector. The second item is the uncertainty in the actual count rates.

To quantify these uncertainties, the average value of the [[ ]] measurements at each of the [[ ]] axial positions is first computed. This is shown in Figure 6-4, which also shows the standard deviation of the measurements made at each axial level. The data for the "measurement reproducibility" is provided in Table 8-2. The uncertainty is highest (exceeds [[ ]]) in Nodes [[ ]], where the signal is the lowest, the flux curvature is the largest, and relatively small differences in the axial position contribute to larger measurement uncertainties. For this reason, these bottom and top nodes are generally not considered in statistical comparisons.

6-5

NEDO-33784 Revision 0 [[ Non-Proprietary Information - Class I (Public) [[

[[ Figure 6-4 Non-Proprietary Average NEDO-33784 Revision Axial Information Values 6-6 for - Class Reference 0 I (Public)

Rod ]]

Figure 6-4 Average Axial Values for Reference ]] [[ Rod [[ ]] ]]

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) plots measured rod, 6.4.2 including zone, the segmented [[ [[ The than this power GE14i the could measured connectors. as bundle, gamma non-connector the so [[ eventually locations bundle. well as [[ identification 6.4.2 [[ ]] Inch Measurements on Rod [[ ]] at isotope to as [[ the scan Figure La [[ ]] segmented isotope rods) was ]] obtain the If Inch 140 [[ would incremental

measured reduce at [[ ]] inch [[ ]] the bottom of the active fuel there measurements spacer rod distribution axial zone, so as to obtain experimental confirmation of the analytic evaluations of the effect of the ]] 6-5 Measurements experimental inch connectors had have segmented isotope rod connectors on the axial power shape of [[ ]]. Figure 6-5 of Non-Proprietary Information the in location. plots the [[ ]], the [[ been [[ the power higher pin

including identification of the bottom and top of each segment in the adjacent segmented isotope bottom due fuel

rod, as well as the spacerpower in the fuel assembly. It is not clear that there is a significant effect on are exposures on NEDO-33784 to confirmation spiking ]]

the measured cumulative La14° distribution due to the connectors in the adjacent segmented isotope rod. As assembly. done on and the the Inch the spiking

[[ Rod connectors axial top at La propensity pins for of the [[ 140 6-7 power exposures It in these each are of Measurements Revision end is the the ]] not exposed in segment - adjacent power shape of for the Class analytic clear the than the adjacent 0 of spiking first I throughout that in fuel fuel (Public) axially [[ ]] evaluations the for ]] there full segmented pins rods segmented the adjacent Rod locations cycle adjacent bottom is immediately early the a [[ significant of of cycle, segmented in isotope isotope of would the positions, residence the ]] ]]. the effect these residence adjacent Figure active rods) be rod. effect isotope higher higher of of which was fuel 6-5 the ]] the on ]], of to

]] Figure 6-5 [[ ]] Inch La140 Measurements for Rod [[ ]] The gamma scan measurements are done at the end of the first full cycle of residence of the GE14i bundle. If there had been power spiking in the adjacent fuel rods early in the residence of this bundle, the incremental pin exposures for these power spiking locations would be higher than non-connector axial location. As the pins are exposed throughout the cycle, these higher power locations would have higher cumulative exposures than axially adjacent positions, which could eventually reduce the power spiking propensity for the fuel pins immediately adjacent to the connectors. [[

6-7

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public)

11 Non-Proprietary NEDO-33784 Information 6 - 8 Revision - Class ]] 0 I (Public)

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) traditional used comparisons, There The measured standard of This 7. independently). deviation without any Both for the Types the second section in approaches measured are GE14i

7. Types of Comparisons making deviation is of La two statistical approach, calculated correction Comparisons 140

This section provides summaries of types of comparisons of design calculations of Ba140 with provides where fuel types measured La140 as a means of demonstrating the GNF capability for calculating nodal pin powers as TIP uncertainty are a for the GE14i fuel assembly. assembly. at means the described comparisons, of approach described summaries by for There are two types of statistical comparisons. The first, described in Section 8, retains the each measured statistical Non-Proprietary taking

traditional statistical approach used by GE in the 1960 - 1985 period for all gammaexperimental scan of and axial

comparisons, where the measured uncertainty at each axial level is used to provide a corrected demonstrating in used in the

standard deviation at each axial level. In this traditional approach, the corrected standard the more of level. uncertainty Section comparisons. where deviation is calculated by taking the square root of the sum of the differences between the square NEDO-33784 square square types by

of the measured uncertainty and the square of the measurement uncertainty (fordetail each axial level uncertainties. GE Information

independently). the In 9, of root of the in uses in this radial, The second approach, described in Section 9, uses an approach similar to the statistical approach comparisons the 7 at Reference - of GNF 1 the

used in making TIP comparisons, where the radial, axial and nodal components are presented each Revision 0 The measurement an the without any correction for experimental uncertainties. traditional axial 1960 approach . capability - sum axial first, Both approaches are described in more detail in Reference 2. Class 2. and of - of level described I the 1985 approach, design similar (Public) nodal uncertainty for differences is calculating period used components calculations to in the the to Section for (for provide between statistical corrected nodal all each of 8, are gamma a pin retains Ba axial the presented corrected approach standard 140 powers square level with scan the

NEDO-33784 Revision 0 8. uncertainty pin-by-pin

Non-Proprietary Information - Class I (Public) In For X-V 8.1 used provides The course These approach. Pin-by-pin [[ measurement measurement deviation infinite Bottom (eliminating The the uncertainty The Comparisons [[ Table previous Traditional Results corrected the Summary statistical detailed fIrst plane 8. Traditional Basis for Gamma Scan Comparisons to ]] ]D, pin-by-pin of predict 8-1 once-burnt of lattice different comparisons for set

In previous GE pin-by-pin gamma scans, repeat measurements on a referenceof rod during the the the the Ba measurements of from in GE Non the course of the experiment were used as a statistical approach to include an the evaluation of the PANAC of for 140 reproducibility average the standard Active reproducibility results experiment the - the TGBLA06 This section Basis - uncertainty in the measurementsStatistica to correct the measured standard deviation. pin-by-pin [[ comparisons quantity Adapted distributions. Bundle the bundle fuel fuel provides comparisons of the Clinton measurements to design calculations using this traditional Ba comparison GE14i measurements Duane Zone. 140 are for approach. 11 measurement of rods assembly deviation Case Off-Line distribution, Non-Proprietary NK690 traditional JYK690 summarized Gamma the {(Predicted l of

JYK690 - Traditional Basis bundle

8.1 Summary - Bundle were Comparisons calculation). were gamma Arnold La is Clinton use For the once-burnt GE14i bundle JYK690, measurements at [[ of ]] axial elevations for 140 [[ (Nodes statistics used individually made. is the

Multiple measurementsare were made on the reference rod.

[[ ]] different fuel rods were made. JYK690, - Scan the at to NEDO-33784 Gamma comparisons reproducibility Traditional scans, [[ multiple

Pin-by-pin measurements of La140 at multiple axial heights are made. The design tools are then and measurements summarized Ba in reference as correct [[ PANACll

used to predict the Ba'4° distribution, and the measured and predicted distributions are compared. Comparisons Multiple Table 140 a the Information Using ]]; In are ]]

The first set of comparisons use the PANACI1 and post-processing programs to predict the repeat statistical measurements / Scan measured if nodes the Measured (similar axial the

8- pin-by-pin Ba140 distributions. 8-1 organized the ]]) ]]. the rod. 1 ]]. Basis for measurements summary Revision documented meas~ements in and measured These pin-by-pin comparison statistics are organizedfor by treating (i.e., normalizing) each comparison of heights where Traditiona While to bundle the - X-Y plane of the fuel assembly individually (similar to the calculation of local peaking in the approach the axial to and For post-processing design Deviation Standard Class La

infinite lattice TGBLA06 calculation). In the summary tablesfollowing in this section, the standard [[ the reference by the at 140 0 predicted slightly Nodes are tables deviation of the quantity {(Predicted Ba140 / Measured La140) -1} is reported,all corrected for the JYK690 ) calculation [[ standard I treating experimental in -I} For all [[ ]] nodes, the average calculations

measurement reproducibility of the reference rod. (Public) made. is l [[ to were Basis Section

]] on measurement reproducibility is [[ ]]; if the comparison is limitedlimited to Nodes [[ [[ in include tables. is rod larger Reproducibility Measurement a (eliminating the [[ ]] nodes where the experimental uncertainty is above distributions made are reported, this The Non-Adapted deviation. reference (i.e., is [[ ]]), the average measurement reproducibility of the reference rod is [[ ]]. programs of 10.1, provided ]] to [[ ]] than section, Note an using design on local uncertainty Nodes nodes,

Comparisons for bundle JYK690 are summarized in the following tables. Note that BAZ is the axial normalizing) ]]. evaluation [[ the corrected

Bottom of the Active Zone. the that As rod this peaking to are elevations reference tools in This [ ]] [[ the JYK690]]. are provided in Table 8-2. [[

PANACI I traditional comparisons for bundle the The detailed can BAZ predict during compared. Table O traditional Corrected Deviation The statistical results are Standard summarized in Table 8-1 for axial Nodes [[ ]]. As can be seen, tT standard is are be average section -Line for

]]. While slightly larger than the [[ of above the corrected standard deviation is [[ in ]] is seen, each then rod. 8-2. the the the the the the for

uncertainty from the]] Duane Arnold Gamma Scan documented in Section 10.1, [[ ]] ]].

Table 8-1 Statistical Comparisons Using the Traditional Basis Non -Adapted Off-Line Corrected Measurement Standard Standard Case Deviation Reproducibility Deviation

Results for Non-Adapted Off-Line (Nodes [[ 1]) (( ]]

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) I ! : I Height BAZ(in) Table 8-2 Results for Non-Adapted Off-Line rr from Corrected Height from Measurement Node Standard Deviation Standard BAZ (in) Reproducibility Deviation 11 I Node Table Non-Proprietary 8-2 NEDO-33784 Revision Standard Results

I Information for Deviation 8 - 2 Non-Adapted - Class 0 Reprodu Measur I (Public) Off-Line e c m ibility e nt Corrected Deviation Standard ]] I I

NEDO-33784 Revision 0 I I I compared: 9 . consideration 9.1 comparison distribution The In Similar bundles Non-Adapted The the the show (off-line Nodes Nodes gamma RMS, Non-ProprietaryNon Information - Class I (Public) . each BA - RMS • • • pin Pin Ada traditional pin a 140 [[ [[ and Rod Pin Axial ? nodal case, scanned surrounding Nodal, cycle to ted nodal,

BA140 / non-adapted values / 9. LA140 Pin Nodal, Rod, and Axial Average Root ]] Mean Square Comparisons LA Nodal Table Off-Line Off- the Average (of the within process, the Average RMS 140 by

The traditional comparison process provides insights as to the comparisonaverage of pin-by-pin power ~ comparison [[ Rod, rod, in axial TIP RMS ~e Pin within an X-Y plane, but the axial shape of the comparison is at eliminated from distribution RMS 9-1 the Table ([[ ([[ when an

This section provides a differentClinton view of the the and

consideration by the normalization process. RMS Case Nodal, and comparison analogous -- RMS normalization calculated average is X-V comparison process, analogous to the techniques common to the TIPof comparison process. ]]. ]] ]] TIP Non-Proprietary formed 9-1 the axial Axial Pin is [[

Similar to the TIP comparison process, the following threenodes). quantities are evaluated and process This plane, greater for are Rod, string. statistics

compared: - Nodal, average RMS. Average Nodes from TIP provided to Pin Nodal RMS TIPs

• ]]) ]]) process, and NEDO-33784 but Table provides than the This process. value -- Rod calculation -- • Rod Average RMS are Axial ]] compared [ ]] [[ Note, statistics the techniques [[ Information - Statistica compares nodal also 9-1 and • Axial Average RMS below. is the axial insights Average a summarizes 9 however, In each case, the RMS is formed from calculation of (Predicted -computed Measured)/Measured values. Axial measure ]], This - RMS following 1 of for Revision to Pin shape which

9.1 Pin Nodal, Rod, and Axial Average Statistical Summary l The to [[ (Predicted RMS compared common Summary measured the section Averaged Nod as the value statistics for the analytical comparisons for the bundle Root The pin nodal, rod, and axial average Class of to off-line of over that analytical a explains gamma gamma scanned at Clinton are providedl below. The off-line non-adapted TIP comparisons the the 0 the three the Mean when provides I

(off-line non-adapted calculated TIPs compared to measuredthe TIPs) documented in Table 4-1 the to - to results pin (Public) comparison TIPs) comparison RMS Comparisons Measured)lMeasured show a cycle average of [[ Rod ]] nodal RMS value when the statistics are taken over non-adapted Nodes the range quantities the scan experimental Square nodal the

]]. This TIP value is a measure of the results of averagingcomparisons over the four

Nodes [[ RMS Average rather documented of ]] for TIP values

bundles surrounding the TIP string. This compares to the gamma scan values of [[ a statistics from [[ averaging RMS, the pin nodal RMS when the statistics are also computed over the range from [[ different comparison Comparisons of dramatic is ]] nodes). Table 9-1 summarizes the pin nodal RMS, the rod average are

]] (of [[ [[ of pin-by-pin TIP eliminated

Note, however, thatthe the experimental uncertainty for

RMS, and the axial average RMS. uncertainty [[ are for evaluated Axial increase in in over

]], ]]. which explains the rather dramatic view Nodes [[ ]] is greater than [[ comparisons rod taken the increase Table RMS ]]. the RMS values in Table 9-1 for Nodes [[ ]] compared to Nodes [[ values. Average process. the average bundle of power ]] ]] from over four and 4-1 the for Table 9-1 Pin Nodal, Rod and Axial Averaged RMSfor Comparisons in

Pin Nodal Rod Average Axial Average Case RMS RMS RMS

Non-Adapted Off-Line ([[ ]]) [[

Non-Adapted Off-Line ([[ ]]) ]]

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) basis measured measurements. shape 9.2 at This eliminated [[ both Summary Figure comparison for in 9.2 Summary Plot of Pin Nodal RMS high the values PANACll in 9-1 and range This comparison provides a summary of the off-line non-adapted results with the gamma scan the

measurements. Plot

Figure 9-1 compares the predicted Ba140 and measured La140 on a pin-by-pin Figure are on-line low provides

basis for the rangePin of Nodes [[ ]] (RMS is [[ ]]). Again, both predicted and of of normalized relative Nodes Pin measured values are normalized to an average value of 1.000. A clear indication of a difference for Nodal 9-1 Non-Proprietary at both high and low relative measured values seems to indicate a challenge to the axial power 3DMTM a Nodal the compares

shape in PANAC11 for the non-adapted core tracking. However, these differences are summary [[ measured Comparisons

eliminated in the on-line 3DMTM shape adapted approach. non-adapted to shape RMS an [[ NEDO-33784 average the of adapted values Information the ]] predicted (RMS for core off-line value 9 seems approach. - 2 Non-Adapted Revision tracking. is of Ba - [[ non-adapted to 1.000. Class 140 indicate and 0 I However, A (Public) measured Case ]]). clear indication a results challenge - Again, Nodes these La with 140 both to [[ the on the differences of predicted gamma a a axial pin-by-pin difference ]] power scan and ]] are

]] Figure 9-1 Pin Nodal Comparisons for Non-Adapted Case - Nodes [[ 11

NEDO-33784 Revision 0 - traditional measurements. pin-by-pin previous differences deviation Table This design This 10. note predicted deviation Clinton The FitzPatrick

Non-Proprietary Information - [[ Class I (Public) Table Conclusions Duane section document 10. Conclusions that 10-1 process - in --- gamma for Ba This section includes conclusions regarding the gamma scan measurements of a GE14i bundle at is December .. the ]] 10-1 gamma approach Arnold is campaign. provides includes corrected 140 Clinton in December of 2011. for Clinton Case eliminated measurement using has for As Clinton -- This document has presented the results of measurements of La140 and thescan comparisons of scans Comparison and can predicted Ba140 for the purpose of confirmation of the power distribution calculations in the the presented first the of conclusions is a campaigns, for FitzPatrick Thus, 20

design process using the traditional statistical approach. In this approach, the measured standard summary [[ purpose be Npn-Proprietary in traditional was previously normalizes - deviation is corrected for the measurement uncertainty at each axial level. In addition, the 11. this the seen, - reproducibility approximately traditional approach first normalizes the data to each axial plane, so the effect ofthe axial shape measurement approach. the

differences is eliminated in this approach. of of results regarding the of [[ because results Axial Traditional NEDO-33784 Number -- statistical results submitted - confirmation

Table 10-1 provides a summary of the corrected standard deviations of various gamma scan the the ]] to the FitzPatrick Clinton ]] measurements. As can be seen, the Clinton results are [[Nodes for corrected Information - provid~d data Inch of of pin-by-pin gamma scans previously submitted to the NRC. The value for the corrected standard of the ]] the [[ for uncertainty approach. the -- 10 ]] than for FitzPatrick, as the [[ results to than deviation for Clinton is [[ measurements to gamma Statistics -- - Clinton Also the 1 ]] for Clinton was approximately [[ ]] of that measured for FitzPatrick. each the Revision [[ of in standard for

note that the measurement reproducibility for the Clinton campaign is comparable to theNRC. the Table are Bundle Clinton ]] ---- FitzPatrick, axial scan

FitzPatrick campaign. Thus, the results for the Clinton campaign are statistically equivalent to Class In campaign of power [[ at previous gamma scan campaigns, because of the [[ for ]] of measured fuel rods. 0 this that The 10-1 measurements deviations each plane, I Gamma The Duane Arnold and FitzPatrick results provided in Table 10-1 are obtained from Reference 2. of campaign (Public) approach, measured value _ distribution are La L- axial Reproducibility as are Measurement 140 so obtained

Table 10-1 Comparison of Traditional Statistics for Gamma Scan Measurementsthe for Scan ]] statistically the and of level. --- of [[ is the Number of Corrected the for various eff~ct Measurement of ]] the measured -- ]] Inch Bundle Measurements Standard Case [[ comparable calculations measured from Reproducibility corrected a FitzPatrick. Axial Nodes Deviation to GE14i In comparisons the of equivalent Reference addition, gamma -- axial Corrected Deviation FitzPatrick Standard fuel - bundle standard standard to in shape rods. Also scan ]] ---- the the the 2 of to at .

NEDO-33784 Revision 0 Non-Proprietary Information - Class I (Public) 2 11. 1. . - Part GE Isotope June GE

11. References References Pin-by-Pin Hitachi Hitachi 2P-A,

1. GE Hitachi Nuclear Energy, "Safety Analysis Report to Support Introduction of GE14i 2009. Isotope Test Assemblies (ITAs) in Clinton Power Station," NEDC-33505P, Revision 0, Test

June 2009. Revision Nuclear Nuclear Assemblies 2. GE Hitachi Nuclear Energy, "Applicability of GE Methods to Expanded Operating Domains Gamma - Pin-by-Pin Gamma Scan at FitzPatrick October 2006," NEDC-33173 Supplement 2 Energy, 1, Non-Proprietary Information Non-Proprietary

Part 2P-A, Revision 1, April 2012. Energy, April Scan (ITAs) 2012. "Applicability at "Safety NEDO-33784 FitzPatrick in Clinton Analysis 11 of - October 1 Revision Power GE Report - Methods Class Station," 2006," 0 to I (Public) to Support Expanded NEDC-33173 NEDC-33505P, Introduction Operating Supplement Revision of Domains GE14i 0, 2 Affidavit for ATTACHMENT NEDC-33787P 5 Revision

ATTACHMENT 5 0

Affidavit for NEDC-33787P Revision 0

(2) I, (1) (3) (4) Affidavit

Global Nuclear Fuel .- Americas Lukas apply The November, described I refers 33787P, determination. and double dotted In LLC Freedom owner Project b. a. Citizen also infonnation those Some secrets" c. The d. forth 18 am

AFFIDAVIT making USC Trosman, qualify infonnation large information Infonnation Infonnation Information Information for Engineering from or and assurance obtain development in for (GNF-A), tenns examples underline to square or Health paragraphs improve v.

NEDC-33787P I, Lukas Trosman, state as follows: (Exemption "Hot Sec. its of analyses, Paragraph in licensee, GNF-A equation Nuclear 2012. this patent under are: withho Infonnation for paragraph

(1) I am Engineering Manager, Reload Design and Analysis, Global Nuclear Fuel - Americas, Cell brackets 1905, Research Group state of application inside his of sought LLC (GNF-A), and have been delegated the function ofpurposes reviewing the information which, sought and which which that Manager, quality, the plans protection. constitutes Inspection lding. (4)a. GNF-A

described in paragraph (2) which is soughtwhere to be withheld, and have been authorized to categories as Regulatory GNF-A competitive objects and 4). (3) discloses narrower definition apply for its withholding. have follows: Global before double (2) discloses Revision reveals to and and if to Act The of NRC or used prevention of be

(2) Thebe information sought to be withheld is contained in GNF-A proprietary report, NEDC- which Reload for proprietary been programs, (4)b. containing this licensing relies ("FOlA"), of a material FOIA withheld 33787P, "Hot Cell Inspection of Clinton Cycle 13 GE14i Rod Segments," Revision 0 datedand withheld square of v. competitive regulations a withholding by aspects Nuclear Commission, Clinton November, 2012. position

0 GNF-A proprietary information in NEDC-33787P is identified by a patentable affidavit, process, FDA, above. information delegated after is AFFIDAVIT a upon dotted underline inside double square brackets. [[Ths_sentence isan examplg.t3}.J] Figures Design competitor, Exemption sought brackets. of of for

and large equationresulting objects containing GNF proprietary information are identified with of the 704 is infonnation is GNF 5 Cycle a in its the double square brackets before and after the object. In all cases,of the superscript notation {3} contained which method, USC Fuel- past, sitnilar considered and 10 object. economic which the F2d "trade subject

refers to Paragraph (3) of this affidavit, which provides the basis for theof proprietary use to the exemption proprietary 975 which CFR determination. 13 [[::rJJi~ design, Analysis, proprietary present, be Sec. in 1280 would 4 exemption by product; function GE14i potential products potential Americas secret", provides withheld, or in, F2d In (3) In making thismatter application for withholding of proprietary information of which it is the 9.17(a)(4), GNF-A's in 552(b)(4), in •• advantage fit (DC apparatus, to ~~p.t~J!~~j~.!!n.~~mP.p.l~t~~!J] all

owner or licensee, respectively, GNF-Amanufacture, relies upon the exemption from disclosure set forth in the GNF-A reduce NEDC-33787P or 871 be into Rod from Global Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act,cases, infonnation Cir. for within uue GNF-A future of information proprietary from

18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), and 2.390(a)(4) for the "trade and (DC the Segments," which competitors his reviewing 1983). secrets" (Exemption 4). The material for which exemption from disclosuredisclosure is here sought and proprietary and the over Nuclear basis including disclosure the have definition

also qualify under the narrowerexpenditure definition of "trade secret", within the meanings assigned to Cir. superscript the Critical 2.390(a)(4) to shipment, it those terms for purposes of FOIAother Exemption 4 in, respectively, Critical Mass Energy meanings Affidavit may for are GNF-A; been Trade for

Project v. Nuclear Regulatory Commission, 975 F2d 1992), 871 (DC Cir. 1992), and Public of is Fuel- Revision customer-funded the set

Citizen Health Research Group v. FDA.companies; 704 F2d 1280 (DC Cir. 1983). supporting identified ihu license without the which identified report, the be is of Mass authorized forth Secrets of infonnation here installation, desirable notation and reasons assigned proprietary Page (4) Some examples of categories of information whichproprietary fit into the defi nition of proprietary Americas, for resources

information are: it NEDC- Figures 0 Energy sought Public in "trade is 1 dated by with Act, data of the a. Information that discloses a process, method, or apparatus, includingthe supporting data set {3} to to to a 3 and analyses, where prevention of its use by GNF-A's competitors without license from GNF-A constitutes a competitive economic advantage over other companies;

b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A;

d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

Affidavit for NEDC-33787P Revision 0 Affidavit Page 1 of 3

(5) (5) (6) (7) (8) (9) Affidavit

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted . knowledge to To A, under subsequent (6) on The originating including information Initial regulatory sensitivity The has the making by The Public harm regulatory customers, Operation, Assembly. the analytical experience contains The the technology with derived The The the subs ' toanalytical NRC in confidence. The information is of a sort customarily held in confidence by GNF- NRC a and the and address GE14i proprietary appropriate been manager procedure "need A, and is tantial in fact so held. The information sought to be withheld has, to the best of my information precise for research, value development a to which approval staff disclosure knowledge and belief, consistently been held in confidence by GNF-A,legitimate no public disclosure (7) is from opportunities. in NEDC-33787P GNP-A's detailed made, any methodology

has been made, and it is not available in public sources. All disclosures to third parties in methodology provisions confidence. Lead to know" following. of investment provisions database for and steps and 10 base, of The component, manager, in it value

including any required transmittals to NRC, have been made, or must be made, pursuant to fact prov'lding of required the CFR was for technical development, the belief, regulatory provisions or proprietary agreements which provide for maintenancedesignation. of the potential confidence. Use evaluation of development, and taken the identified and so need of information approval information in confidence. Its initial designation as proprietaryresults information, and the competitive of licensed of proprietary technology 2.390 that Assembly, basis. held. the subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs it or cognizant its the project of consistently or The the transmittals to The analyses o the for is is Revision proprietary (6) and (7) following. and constitutes content, the time commercial information customers, prevent difficult proprietary expertise regarding (b) not information GEl4i process. The in of information to (6) Initial approval of proprietaryincludes treatment of a document is made by the manager of the Disclosures person engineering, manager, (4), and Its external paragraph GNP-A. available evaluation, in position information, was originating component, the person most likely to be acquainted with the value and treatment base done marketing information 0 competitive relation initial its the money to

sensitivity of the information in relation to industry knowledge, or subject to the terms been to Lead agreements. a to achieved h in-reactor the unauthorized quantify, and major most development value In under which it waswith licensed to GNF-A. Access to such documents within GNF-A is limited information NRC, goes sought agreements release devise is principal Access is held and on a "need to know" basis. in addition, designation (2), by their outside part Use of of design to NRC-approved analytical, public function GNF-A likely extends beyond have and GNF-A. foreclose a sought in a at industry

The procedure for approval of externalto release of such a document typically requires review

(7) above, effect, an of but of sort agents, Assembly document to confidence by the staff manager, project manager, principal scientista or other equivalent authority, by be such then GNF-A's scientist evaluation significant details been GNF-A such it sought disclosure, the sources. which to customarily the manager of the cognizantof marketing function (or his delegate), and by the Legal asset. withheld performance clearly beyond to the is (or and as

Operation, for technicalthe content, competitive effect, and determination of the accuracy of be a only and knowledge, technology or suppliers, made, documents be classified document

the proprietary designation. Disclosures outside GNF-Aand are limited to regulatory bodies, extensive proprietary his to determination expertise reduce provide acquainted is are or methods. withheld is comprehensive by NRC is in customers, and potential customers, and their agents, suppliers, and licensees, and others All be the cost process made performance, other delegate), is substantial. or derived are limited GNF-A, with a legitimate need for the information, and then only in accordanceaccordance with appropriate held withheld disclosures original likely must

agreements. to and regulatory provisions or proprietarythe review of as as typically within base for equivalent or by to GNF-A. physical in has, set proprietary the and information, availability licensees, to be Affidavit with subject (8) The information identifieddetermine in paragraph (2), above, is classified as proprietary because it confidence from to maintenance the no forth includes of and is development regulatory to made,

contains detailed results regarding the in-reactor performanceGEl4i of the GE14i Lead Use costs GNF-A apply cause public with BWR as being manager the requires to the

Assembly. The development, evaluation, design details and performance, as they relate to the the by database in they authority,

cost to GNF-A. to the GE14i Lead Use Assembly, was achieved at a significant third accuracy comprise Page appropriate pursuant best the paragraphs substantial and value safety because Lead the and disclosure submitted the the extensive of is by relate and bodies, limited correct review

from the extensive parties The development of the GE14iprofit Lead Use Assembly is derived of of of others 2 GNF Legal apply value terms cost. of Use

and a major GNF-A asset. and experience database that constitutes and my the the the by of to to it 3 a (9) Public disclosure of the information sought to be withheld is likely to cause substantial harm to GNF-A's competitive position and foreclose or reduce the availability of profit- making opportunities. The information is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from provkling analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

Affidavit for NEDC-33787P Revision 0 Affidavit Page 2 of 3

Executed true and I Affidavit

GNF-A's competitive advantage will be lost if its competitors are able to use the results of declare conclusions. GNF-A's GNF-A's the the required advantage an The these the GNF-A experience to normalize or verify their own process or if they are able to claim with

an equivalent understanding by demonstrating that they can arrive at the same or similar equivalent GNF-A correct public. value under on for very conclusions. a this NEDC windfall, to competitive competitive valuable of to penalty

The value to of this information to GNF-A would be lost if the information were disclosed to undertake experience 12th Making this the best the public. Making such information available to competitors without their seek having been understanding - 33787P

required to undertake a similar expenditure of resources would unfairly provide competitorsday infonnation and an of with a windfall, and deprive GNF-A of the opportunity to exercise its competitive analytical of such a perjury of advantage advantage advantage to seek an adequate return on its large investment in developing and obtaining adequate to similar deprive November Revision these very valuable analytical tools. my nonnalize information knowledge, by tools. that I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are to expenditure return Engineering Lukas Global GNF-A demonstrating GNF-A will true and correct to the best will 0 of my knowledge, information, and belief. the 2012. or be foregoing on Tro Nuclear verify Executed on this 12th day of November 2012. available information, lost would of its ' sman of Manager, if large the their resources would resources its that Fuel- be affidavit to opportunity competitors investment lost own competitors they and Reload Atnericas, if

Lukas Trosman process belief. can the Engineering Manager, Reload Design and Analysis and information arrive Global Nuclear Fuel - Americas, LLC the Design are in to unfairly provide unfairly or without LLC developing matters exercise able if at they and Affidavit to h same the their were stated use Analysis are its and the able having disclosed competitive cOlnpetitors Page therein or obtaining results to similar 3 claim been of are of to 3

Affidavit for NEDC-33787P Revision 0 Affidavit Page 3 of 3 Affidavit for ATTACHMENT NEDC-33784P 6 Revision

ATTACHMENT 6 0

Affidavit for NEDC-33784P Revision 0

(2) I (1) (3) (4) (5) NEDC-33784P , Global Nuclear Fuel - Americas Atul The which have provides I within proprietary owner In In Gamma information Freedom those Citizen Project b. secrets" also a. information c. Some To d. The 18 forth to am A. NRC making AFFIDAVIT all USC address qualify information information Information Information Information Information Engineering and or from assurance development been Karve, obtain in terms is cases, examples or double Health paragraphs improve v. I, Atulin A. Karve, state as follows: (Exemption sought the Scan Sec. of analyses, licensee, GNF-A delegated confidence. Revision Nuclear this information 10 patent under are: in Information basis for state (1) 1 am Engineering Manager, Methods, Global Nuclear Fuel - Americas, LLC (GNF-A), andthe 1905, Research CFR figures at square of to application

have been delegated the functionhis of reviewing the information described in paragraph (2) purposes of sought which which, sought which that superscript Manager, for quality, be as the Clinton plans protection. constitutes

which(4)a is sought to be withheld, and have been authorized to apply for its withholding. where categories 0 2.390 GNP Regulatory competitive 4). and follows: the withheld, the discloses narrower is brackets. . Global . The within discloses reveals and Group and (2) to

The information sought to be withheldif is contained in NEDC-33784P, to identified Act

GE14i Pin-by-Pin function proprietary -A The NRC or (b) used prevention of December

Gamma Scan at Clinton December 2011, be be Revision 0, dated October 2012. Methods, for

information GNF-A programs, (4)b. licensing relies notation ("FOIA"), material a (4), proprietary information within the text and tables is identified byFOIA a dotted underline placed withheld withheld the of and have v. regulations definition competitive a withholding aspects by Nuclear Commission. position within double square brackets. [[Ths_.sentence_ is ..an. example [3}]] [[Thi~

patentable GNF-A proprietary process, FDA, above. of information the text AFFIDAVIT with a information in figures is identified with double square brackets before and afterupon the object. determination. competitor, reviewing Exemption Global infonnation of of 2011, .. {3} In all cases, the superscript notation (3} refers to Paragraph (3) of for this affidavit, which resulting and of ~.~D~~D£~j~ 704 is is double is 5 been a in

provides the basis for the proprietary determination.its the of refers USC which of method, Fuel- past, similar contained considered tables 10 economic the F2d subject "trade of use a Nuclear Revision authorized (3) In making this application for withholding of proprietary information of whichexemption it is the 975 sort which CFR design, square the proprietary present, Sec. in to 1280 would 4 by owner or licensee, GNF-A relies upon the exemption from disclosureexemption set forth in the is product; sought potential .. Americas customarily secret", or in, F2d information Paragraph matter 1m

Freedom of Information Act ("FOIA"), 5 USC Sec. 552(b)(4), and the Trade Secrets Act, identified 9.l7(a)(4), GNF-A's 552(b)( in Fuel- advantage fit (DC apparatus, to .. brackets

18 USC Sec. 1905, and NRC regulations 10 CFR 9.17(a)(4), respectively, and 2.390(a)(4) for "trade manufacture, 0, reduce his ~~~.p.l~ NEDC-33784P, or to 871 be into from secrets"to (Exemption 4). The material for which exemption from disclosure is here sought dated Cir. for within apply future products information be proprietary 4), from

also qualify under the narrower definition of "trade secret", within the meanings assigned to Americas, (DC the by which competitors (3) held withheld disclosure those terms for purposes of FOIA Exemption 4 in, respectively,1983). Critical Mass Energy before and and described .. over other ~~!J] including for a October GNF-A disclosure the Project v. Nuclear Regulatory Commission, 975 F2ddefinition 871 (DC Cir. 1992), and Public expenditure of Cir. dotted in the 2.390(a)(4) its Critical to shipment,

Citizen Health Researchit Group v.-FDA , 704 F2d 1280 (DC Cir. 1983). meanings this Affidavit confidence and GNF-A may LLC GNF-A; withholding. Trade for 1992), of is GE14i underline (4) Some examples of categoriescustomer-funded of information which fit into the definition of proprietary in affidavit, set 2012. being after companies; supporting without which the be (GNF-A), of information are: is paragraph Mass forth Secrets of here installation, desirable and Page proprietary reasons assigned proprietary Pin-by-Pin the for submitted resources

by a. Information that discloses a process, method, or apparatus, including supporting data it GNF-A Energy license object. placed sought Public in which and analyses, where prevention of its use by GNF-A's competitors"trade without license is GNF- 1 Act, data of and the

from GNF-A constitutes a competitive economic advantage over other companies;the (2) set to to 3 b. Information which, if used by a competitor, would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing of a similar product;

c. Information which reveals aspects of past, present, or future GNF-A customer-funded development plans and programs, resulting in potential products to GNF-A; d. Information which discloses patentable subject matter for which it may be desirable to obtain patent protection.

The information sought to be withheld is considered to be proprietary for the reasons set forth in paragraphs (4)a. and (4)b. above.

(5) To address 10 CFR 2.390 (b) (4), the information sought to be withheld is being submitted to NRC in confidence. The information is of a sort customarily held in confidence by GNF-

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(6) (7) (8) (9) NEDC A, and is in fact so held. The information sought to be withheld has, to the best of my A, A, originating Initial under has regulatory knowledge (6) on including The by sensitivity subsequent information the Operation, the with The customers, The regulatory making harm experience GE14i Public significant detailed The The technology the derived analytical substantial analytical The the knowledgeGNP-A's and belief, consistently been held in confidence by GNF-A, no public disclosure - 33784P a and and the and proprietary GNF-A been manager appropriate procedure "need has been made, and it is not available in public sources. All disclosuresinformation to third parties precise research, development a value which to approval staff Isotope disclosure legitimate

including any required transmittals to NRC, have been made, or must be made, pursuant to (7) is opportunities. from results GNP-A's made, any competitive in regulatorymethodology provisions or proprietary agreements which provide for maintenance of the methodology provisions following. Revision of cost to provisions and database investment for and steps base, of component, experience manager, in Its initial designation as proprietary information, and the it value information in confidence. fact providing know" of required the was for technical Test development, belief, the to designation. potential including

subsequent steps taken to prevent its unauthorized disclosure, are as set forth in paragraphs confidence. of evaluation and identified taken the and so need GNP information approval of

(6) and (7) following. competitive of of licensed proprietary technology Assembly. 0 that basis. held it the or cognizant project its advantage the consistently the of or -A. The transmittals to to for analyses is

(6) Initial is approval of proprietary treatment of a document is made by the manager of the proprietary and constitutes content, the time c9mmercial infonnation customers, prevent proprietary normalize difficult the expertise not

originating component, the person most likelyGE14i to be acquainted with the value and in the · The infonnation of process. to includes

sensitivity of the information in relation to industry knowledge, or subjectDisclosures to the terms person engineering, manager, process Its paragraph and external GNP-A. available in position infonnation, treatment The base

under which it was licensed'to GNF-A. Access to such documents within GNF-A is limited information marketing done will competitive relation initial its money Isotope to been

on a "need to know" basis. to agreements. a to GE14i or unauthorized quantify, and major most be development value In NRC, with goes sought agreements and release devise verify principal Access is

(7) The procedure for approval of external release of such a document typically requires review held and in lost (2) diin the addition, designation their by outside of part to methodology by the staff manager, NRC-approved project manager, principal scientist or other equivalent authority, by Test analytical, public function Isotope likely GNF-A extends beyond have and is GNP-A. sought foreclose if in a industry

the manager of the cognizant marketingto function (or his delegate), and by the Legal their effect, an of but ofGNF-A's classified agents, its document to confidence Assembly

Operation, for technical content, competitivebe effect, and determination of the accuracy of then such scientist evaluation been GNF-A such competitors it sources. disclosure, which Disclosures outside GNF-A are limited to regulatory bodies, to of own the proprietary designation. Test asset. withheld clearly beyond to the (or and as the only be

customers, and potential customers, and their agents, suppliers, and licensees, and othersa and knowledge, technology or suppliers, made, documents be document process Assembly for .

with a legitimate need for theextensive information, and then only in accordance with appropriate as proprietary his determination provide expertise reduce acquainted or are is methods. withheld by comprehensive NRC agreements. All is is regulatory provisions or proprietary in proprietary the the process made other delegate), is or substantial. are limited GNP accordance derived are disclosures original or likely design · (8) The information identified in paragraph (2) is classified as proprietary because it contains must and review the as typically able within base for equivalent has -A, if or by to

detailed results including the physical process and methodology for the design and analysis of the has, set and they information, availability licensees, to be with Affidavit subject GE14i Isotope Test Assembly.determine The GE14i Isotope Test Assembly has been developed at a maintenance the no to been to from and because forth includes of and development regulatory to cost to GNF-A. made, costs significant GNF-A apply cause use public are with BWR manager the requires to the the analysis developed by the database in the able authority, to The development of the GE14i Isotope Test Assembly is derived from the extensive third accuracy comprise best appropriate pursuant Page the paragraphs substantial and value it safety the disclosure and the the of extensive results experience database that constitutes a major GNF-A asset. is contains to and bodies, limited correct review parties profit of of of others of 2 Legal apply terms claim value

Public disclosure of the informationcost. sought to be withheld is likely to cause substantial of at and and (9) and my the the the the by of of to 3 a harm to GNF-A's competitive position and foreclose or a reduce the availability of profit- making opportunities. The information is part of GNF-A's comprehensive BWR safety and technology base, and its commercial value extends beyond the original development cost. The value of the technology base goes beyond the extensive physical database and analytical methodology and includes development of the expertise to determine and apply the appropriate evaluation process. In addition, the technology base includes the value derived from providing analyses done with NRC-approved methods.

The research, development, engineering, analytical, and NRC review costs comprise a substantial investment of time and money by GNF-A.

The precise value of the expertise to devise an evaluation process and apply the correct analytical methodology is difficult to quantify, but it clearly is substantial.

GNF-A's competitive advantage will be lost if its competitors are able to use the results of the GNF-A experience to normalize or verify their own process or if they are able to claim

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true I Executed NEDC-33784P an equivalent understanding by demonstrating that they can arrive at the same or similar declare and an an The these conclusions. the with required conclusions. advantage equivalent equivalent correct public. under value on very The value of this information to GNF-A would be lost if the information were disclosed to a this windfall, the public. Making such information available to competitors without their having been to of valuable to penalty Revision to required to undertake a similar expenditure of resources undertake would unfairly 9th provide competitors Making this the seek understanding with a windfall, and deprive GNF-A of the opportunity to exercise its competitive understanding day best

advantage to seek an adequate return on its large investment in developing and obtaining information and an of analytical of 0 these very valuable analytical tools. such perjury a of adequate October similar deprive I declare under penalty of perjury that the foregoing affidavit and the matters stated therein are my information

true and correct to the best of my knowledge, information, and belief. knowledge, by tools. that to expenditure 2012. return ~ Engineering Global Atul demonstrating GNF-A GNF-A

Executed on this 9th day of October 2012. the A. foregoing on Nuclear available Karve information, would of its JlC\l- of Manager, large the resources that Fuel- L.(.Q...... be affidavit to opportunity investment lost competitors they and Americas, Methods if would Atul A. Karve ~ belief. can the Engineering Manager, Methods and information arrive Global Nuclear Fuel - Americas, LLC the in to unfairly without LLC developing matters exercise at Affidavit the provide their were stated same its and having disclosed competitive competitors Page therein or obtaining similar 3 been of are to 3

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